preface
preface
preface
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8.10. TAX TREATIES<br />
136<br />
TAXATION<br />
As of January 2011, Israel is party to some 50 double taxation treaties. Part of<br />
these have recently been signed, while in the case of others, the Ministry of<br />
Finance is holding discussions with the relevant countries with a view to<br />
renewing the treaties, usually by applying all or part of the provisions of the<br />
OECD model.<br />
Meanwhile, new double taxation treaties were recently signed with Denmark<br />
and the U.K., designed to replace the old ones. Furthermore, a treaty has for<br />
the first time been signed with Georgia. These are expected to become effective<br />
once they have been ratified by Israel and the relevant countries.<br />
8.10.1. Treaty Withholdings<br />
The following table summarizes withholding tax rates on dividends,<br />
interest and royalties in accordance with various tax treaties. It should<br />
be noted that the data listed below are subject to specific provisions of<br />
each treaty.<br />
Dividends<br />
%<br />
Interest<br />
%<br />
Royalties<br />
%<br />
Non-treaty countries 20/25 Variable 25<br />
Austria 25 15 0/10<br />
Belarus 10 5/10 5/10<br />
Belgium 15 15 0/10<br />
Brazil 10/15 15 10/15<br />
Bulgaria 10/12.5 5/10 12.5<br />
Canada 15 15 0/15<br />
Croatia 5/10/15 5/10 5<br />
China 10 7/10 10<br />
Czech Republic 5/15 10 5<br />
Denmark** 5/15/25 25 10<br />
Ethiopia 5/10/15 5/10 5<br />
Estonia 0/5 5 0<br />
Finland 5/15 10 10<br />
France 5/10/15 0/5/10 0/10<br />
BDO Israel