Summary of Tax Treaty Rates

As of 06 February 2015

Country
Australia
Austria
Bahrain
Bangladesh
Belgium
Brazil
Canada
Chile

Dividends
Individuals
Qualifying
Companies
Companies
25%
15%1
25%
10%4
15%
10%7
15%
10%9
15%
10%10
25%
15%11
25%
15%14
15%
10%17

Interest
15%/10%2
15%/10%5
10%
15%
10%
15%/10%12
15%/10%15
10%

Royalties
25%/15%3
15%/10%6
15%8/10%
15%
15%
25%13/15%
25%16
15%181019

1

This rate applies if relief by way of either rebate or credit (in accordance with Article 24 of the
RP-Australia Tax Treaty) is granted to the beneficial owner of the dividends.
2
The lower rate applies to public issues of bonds, debentures or similar obligations, paid by a
Philippine company to an Australian resident.
3
The lower rate applies if the royalties are paid by an enterprise which is registered with the
Board of Investments and engaged in preferred areas of activities.
4
This rate applies if the beneficial owner is a company which holds directly at least 10% either of
the voting shares of the company paying the dividends or of the total shares issued by that
company during the period of six months immediately preceding the date of payments of the
dividends.
5
The lower rate applies to interest paid on public issues of bonds, debentures or similar
obligations; and to interest paid by a company registered with the Board of Investments and
engaged in preferred pioneer areas of investment under the investment incentives laws of the
Philippines.
6
The lower rate applies to royalties paid by a company registered with the Board of Investments
and engaged in preferred pioneer areas of investments under the investment incentives laws of
the Philippines.
7
This rate applies if the beneficial owner is a company (excluding partnerships) which holds
directly at least 10% of the capital of the paying company.
8
This rate applies to royalties arising from the use of, or the right to use, any copyright of literary,
artistic or scientific work including cinematograph films or tapes for television or broadcasting.
The rate is 10% for other royalties.
9
This rate applies if the beneficial owner is a company (excluding partnerships) which holds
directly at least 25% of the capital of the company paying the dividends.
10
This rate applies if the beneficial owner is a company which holds directly at least 10% of the
capital of the company paying the dividends.
11
This rate applies if the recipient is a company including a partnership.
12
The lower rate applies to interest paid on public issues of bonds, debentures or similar
obligations.
13
This rate applies to royalties arising from the use or the right to use trade marks and
cinematograph films, films or tapes for television or radio broadcasting. The rate is 15% for other
royalties.
14
This rate applies if the beneficial owner is a resident of Canada which controls at least 10% of
the voting power of the company paying the dividend.
15
The lower rate applies to interest paid on public issues of bonds, debentures or similar
obligations.
16
This rate is subject to the “most-favored-nation” provision of the treaty.
17
This rate applies if if the beneficial owner is a company which holds directly at least 10 per cent
of the capital of the company paying the dividends
18
This rate applies to royalties arising from the use of, or the right to use, any copyright of literary,
artistic or scientific work including cinematograph films or tapes for television or broadcasting.
19
This rate applies to royalties arising from the use of, or the right to use, any patent, trade mark,
1

plan. or from the use of. design or model. 23 This rate applies if the beneficial owner is a company which holds directly at least 10% of the capital of the company paying the dividends. or the right to use. 20 This rate applies if the beneficial owner is a company which holds directly at least 10% of the capital of the company paying the dividends. Error: Reference source not found). trade mark. commercial or scientific experience. artistic or scientific work. or from the use of. 28 The lower rate applies to interest on public issues of bonds. 30 This rate applies if the beneficial owner is a company (excluding partnerships) which holds directly at least 10% of the voting shares of the company paying the dividends. 27 This rate applies if the recipient is a company (excluding partnership) owning at least 10% of the voting stock of the company paying the dividends. any copyright of cinematograph films. any patent. 35 This rate applies to royalties arising from the use of. or the right to use. plan. secret formula or process. secret formula or process. or scientific equipment. or the right to use.Summary of Tax Treaty Rates As of 06 February 2015 Country China Czech Republic Denmark Finland France Germany Hungary India Dividends Individuals Qualifying Companies Companies 15% 10%20 15% 10%23 15% 10%26 15% 15%27 15% 10%30 15% 10%33 20% 15%37 20% 15%39 Interest 10% 10% 10% 15%/10%28 15%/10%31 15%/10%34 15% 15%/10%40 Royalties 15%21/10%22 15%24/10%25 15% 25%/15%29 25%/15%32 15%35/10%36 15%38 15%41 design or model. commercial. 29 The lower rate applies to royalties paid by an enterprise registered with and engaged in preferred areas of activities and also to royalties in respect of cinematographic films or tapes for television or broadcasting. trade mark. 31 The lower rate applies with respect to public issues of bonds. industrial. or to any loan of whatever kind granted by a bank. or the right to use. or for information concerning industrial. artistic or scientific work including cinematograph films or tapes for television or broadcasting. and royalties for the use of. artistic or scientific work (other than those mentioned in footnote no. design or model. secret formula or process. 24 This rate applies to royalties arising from the use of. 2 . and films or tapes for television or radio broadcasting. 26 This rate applies if the beneficial owner is a company (other than a partnership) which holds directly at least 25% of the capital of the company paying the dividends. or scientific equipment. any patent. 32 The lower rate applies if the royalties are paid by an enterprise registered with the Philippine Board of Investments and engagded in preferred areas of activities. commercial or scientific equipment. artistic or scientific work including cinematograph films or tapes for television or broadcasting. provided that the contract giving rise to the royalties has been approved by the Philippine competent authorities. plan. commercial or scientific equipment. commercial or scientific experience. or the right to use. any copyright of literary. or for information concerning industrial. or the right to use. or paid in respect of cinematographic works recorded for broadcasting or television 33 This rate applies if the beneficial owner is a company (excluding partnerships) which holds directly at least 25% of the capital of the company paying the dividends. or the right to use any copyright of literary. any copyright of literary. commercial or scientific experience. commercial. debentures or similar obligations. or for information concerning industrial. or the right to use. or from the use of. 22 This rate applies to royalties arising from the use of. 25 This rate applies royalties arising from the use of. debentures or similar obligations. or to public issues of bonds. debentures or similar obligations. 21 This rate applies to royalties arising from the use of. industrial. any copyright of literary. industrial. or the right to use. 34 The lower rate applies to interest paid on the sale on credit of any industrial.

trade mark. 44 This rate applies if the beneficial owner is a company (excluding partnership) which holds directly at least 10% of the capital of the paying company. secret formula or process. or the right to use. 42 This rate applies if the beneficial owner is a company which holds directly at least 25% of the capital of the paying company. 48 This rate applies if the beneficial owner is a company which holds directly at least 10% either of the voting shares of the company paying the dividends or of the total shares issued by that company during the period of six months immediately preceding the date of payment of the dividends. This rate also applies to interest paid by a company. This rate also applies if the dividends are paid by a company registered with the Board of Investments and engaged in preferred pioneer areas of investment under the investment laws of the Philippines. or the right to use. 46 The lower rate applies to interest in respect of public issues of bonds. industrial. or similar obligations. commercial. 39 This rate applies if the beneficial owner is a company which owns at least 10% of the shares of the company paying the dividends. 38 This rate is subject to the “most-favored-nation” provision of the treaty. 41 This rate applies if the royalties are paid by an enterprise which is registered with the Board of Investment. 52 This rate applies to interest paid in respect of public issues of bonds. commercial or scientific experience. or from the use of. 47 The lower rate applies to royalties paid by an enterprise registered with the Philippine Board of Investments and engaged in preferred areas of activities and also royalties in respect of cinematographic films or tapes for television or broadcasting. registered with the Board of Investments and engaged in preferred pioneer areas of investment under the investment incentives laws of the Philippines.Summary of Tax Treaty Rates As of 06 February 2015 Country Indonesia Israel Italy Japan Korea Malaysia Myanmar Netherlands Dividends Individuals Qualifying Companies Companies 20% 15%42 15% 10%44 15% 15% 15% 10%48 25% 10%51 54 25%/15% 15% 15% 10%56 15% 10%57 Interest Royalties 15%/ 10% 15%/10%46 10% 15%/10%52 15% 25%/15%43 15%45 25%/15%47 15%49/1050 15%/10%53 25%/15%55 15%/10%58 15%/10%59 36 This rate applies to royalties arising from the use of. debentures or similar obligations. 40 The lower rate applies if the interest is received by a financial institution (including insurance companies) or in respect of public issues of bonds. or scientific equipment. This rate also applies if royalties were paid by companies regeisters with the Board of Investments and engaged in preferred pioneer areas of investment under the investment incentive laws of the Philippines. debentures or similar obligation. being a resident of the 3 . 43 The lower rate applies to royalties paid by an enterprise registered with the Philippine Board of Investments. and engaged in preferred areas of activities as determined by the said Board. being a resident of the Philippines. 37 This rate applies if the beneficial owner is a company which holds directly at least 25% of the capital of the company paying the dividends. any patent. plan. debentures. 49 This rate applies if the royalties are paid in respect of the use of or the right to use cinematograph films and films or tapes for radio or television broadcasting 50 Lower rate applies for other royalties. design or model. 51 This rate applies if the beneficial owner is a company (other than a partnership) which holds directly at least 25% of the capital of the company paying the dividends. This rate applies also if the dividends are paid by a company. 45 This rate is subject to the “most-favored-nation” provision of the treaty. or for information concerning industrial.

54 This rate applies if the recipient is a company. 57 This rate applies if the recipient is a company the capital of which is wholly or partly divided into shares and which holds directly at least 10% of the capital of the company paying the dividends. 65 This rate is subject to the “most-favored-nation” provision of the treaty. or any other financial institution. 56 This rate applies if the recipient is a company the capital of which is wholly or partially divided into shares and which holds directly at least 10 per cent of the capital of the company paying the dividends. 60 This rate applies if the beneficial owner is a company (excluding partnerships) which holds directly at least 10 per cent of the capital of the paying company.5%60 15% 15%61 25% 15%64 25% 15%67 15% 10%70 15% 10%71 15% 10%72 15% 15% Interest 10%62 15% 15%/10%68 10% 10% 15%/10%73 15% Royalties 15%63 25%65/7. However. debentures or similar obligations. 69 The lower rate applies if the royalties are paid by an enterprise registered with and engaged in preferred areas of activities. 58 The lower rate applies to interest in connection with the sale on credit of any industrial.Summary of Tax Treaty Rates As of 06 February 2015 Country Nigeria New Zealand Norway Pakistan Poland Qatar Romania Russian Federation Dividends Individuals Qualifying Companies Companies 15% 12. if the company which is a resident to the Netherlands suffers Netherlands company tax on the dividends which it receives from the company which is a resident of the Philippines. commercial or scientific equipment. 72 This rate applies if the recipient holds at least 25% of the outstanding shares of the voting stock of the paying corporation during the taxable year which precedes the date of payment of the 4 . 62 This rate applies if the recipient is the beneficial owner of the interest. 63 This rate applies if the recipient is the beneficial owner of the royalties. 68 The lower rate applies if the interest is paid with respect to public issues of bonds. or in respect of public issues of bonds. 71 This rate applies if if the beneficial owner is a company (excluding partnerships) which holds directly at least 10 per cent of the capital of paying company. registered with the Board of Investments and engaged in preferred pioneer areas of investment under the investment incentives laws of the Philippines. 59 The lower rate applies to royalties paid by an enterprise registered and engaged in preferred areas of activities. 66 This rate applies to gross rentals or amount paid for the use of or the right to use containers. 53 The lower rate applies to royalties paid by a company registered with the Board of Investments and engaged in preferred pioneer areas of investment under the investment incentives laws of the Philippines. the 15% rate will apply. or tapes for radio or television broadcasting. cinematograph films. 64 This rate applies if the beneficial owner is a company which controls directly or indirectly at least 10% of the voting power in the company paying the dividends. or the right to use. debentures or similar obligations. on any loan of whatever kind granted by a bank. 55 This rate applies to royalties paid by a registered enterprise and to royalties paid for the use of.5%66 25%/15%69 15% 15% 25%/15%74/10%75 15% Philippines. 70 This rate applies if the beneficial owner is a company (excluding partnerships) which holds directly at least 25 per cent of the capital of the paying company. 67 This rate applies if the recipient is a company (excluding partnership) which holds 25% of the capital of the paying company during the taxable year which precedes the date of payment of the dividends and during the whole of its prior taxable year. 61 This rate applies if the beneficial owner is a company.

77 The lower rate applies if the interest is paid with respect to public issues of bonds. or the right to use. secret formula or 5 . or in respect of cinematographic films or tapes for television or broadcasting. 87 The lower rate applies if the interest is in respect of public issues of bonds. design or model. any patent. trade mark. 83 This rate applies if the beneficial owner is a company (excluding partnerships) which holds directly at least 25% of the capital of the paying company. plan. debentures or similar obligations. 89 This rate applies if the beneficial owner is a company (excluding partnerships) which holds directly at least 25 per cent of the capital of the paying company. 78 This rate applies to royalties paid by an enterprise registered with the Board of Investments and engaged in preferred pioneer areas of activities and also to royalties paid on cinematographic films and tapes for television or broadcasting. debentures or similar obligations. or on public issues of bonds. artistic or scientific work. 91 This rate applies for royalties arising from the use of. debentures or similar obligations offered to the general public. 81 This rate applies to royalties paid on cinematographic films or tapes for television or broadcasting. 79 This rate applies if the if the recipient is a corporation (excluding partnership) which holds directly at least 10% of the voting shares of the company paying the dividends. 73 This rate applies to interest paid in connection with the sale on credit of any industrial. 74 This rate applies to royalties paid on cinematographic films and tapes for television or broadcasting. or on any loan of whatever kind granted by a bank. or the right to use. commercial or scientific machine or equipment or similar installation. 76 This rate applies if the recipient is a company (including partnership) which holds at least 15% of the outstanding shares of the voting stock of the paying company during the taxable year which precedes the date of payment of the dividends and during the whole of its prior taxable year. any copyright of literary. 84 This rate applies if the beneficial owner is a company (excluding partnerships) which holds directly at least 10% of the capital of the paying company.Summary of Tax Treaty Rates As of 06 February 2015 Country Singapore Spain Sweden Switzerland Thailand Turkey United Arab Emirate United Kingdom Dividends Individuals Qualifying Companies Companies 25% 15%76 15% 10%79 15% 10%83 15% 10%84 15% 20%85 15% 10%89 15% 10%92 25% 15%94 Interest 15%/10%77 15%/10%80 10% 10% 25%86/15%/10%87 10% 15%/ 10%93 15%/10%95 Royalties 25%/15%78 15%/20%81/10%82 15% 15% 25%/15%88 15%90/ 10%91 10% 25%/15%96 dividends and during the whole of its prior taxable year. 82 This rate applies to royalties paid by an enterprise registered with the Philippine Board of Investments and engaged in preferred areas of activities. commercial or scientific equipment and in respect of issues of bonds. debentures or similar obligations. 85 This rate applies if the Thai paying company is not engaged in an industrial undertaking 86 This rate applies if the interest arises from Thailand. Apply the 15% rate if the interest arises from the Philippines. any cinematograph films or tapes for television or radio broadcasting. 88 This rate applies to royalties paid by an enterprise registered with the Philippine Board of Investments and engaged in preferred areas of activities. 90 This rate applies for royalties arising from the use of. 80 This rate applies if the interest is paid in connection with the sale on credit of any industrial. 75 This rate applies to royalties paid by an enterprise registered with the Board of Investments and engaged in preferred pioneer areas of activities.

commercial. the 15% rate in the RP-Netherlands Tax Treaty and RP-China Tax Treaty may be applied under the mostfavored-nation” provision of the RP-US Tax Treaty. or scientific equipment. or the right to use. 2003. industrial. or from the use of. 101-03 dated July 24. In ITAD Ruling No. 100 This rate applies if the recipient is the beneficial owner is a company (excluding partnerships) which holds directly at least 25% of the capital of the paying company. 98 This rate applies to interest with respect to public issues of bonded indebtedness. or for information concerning industrial. 6 . This rate is also subject to the “mostfavored-nation” provision on the treaty. 99 This rate applies to royalties paid by a corporation registered with the Philippine Board of Investments and engaged in preferred areas of activities. or in respect of cinematograph films or tapes for television or radio broadcasting. 92 This rate applies if the beneficial owner is a company (excluding partnerships) which holds directly at least 10 per cent of the capital of the paying company.Summary of Tax Treaty Rates As of 06 February 2015 Country United States of America Vietnam Yugoslavia Dividends Individuals Qualifying Companies Companies 25% 20%97 15% 10%100 15% 10%101 Interest 15%/10%98 15% 10% Royalties 25%/15%99 15% 15% process. 94 This rate applies if the beneficial owner is a company which controls directly or indirectly at least 10% of the voting power in the company paying the dividends. 93 This rate applies if the beneficial owner is a company (excluding partnerships) which holds directly at least 10 per cent of the capital of the paying company. 95 The lower rate applies if the interest is paid by a company in respect of the public issue of bonds. debentures or similar obligations. commercial or scientific experience. 97 This rate applies if the recipient is a corporation which holds at least 10% of the outstanding shares of the voting stock of the paying corporation during the part of the paying corporation’s taxable year which precedes the date of payment of the dividend and during the whole of its prior taxable year. 96 This rate applies to royalties paid by an enterprise registered with the Philippine Board of Investments and engaged in preferred areas of activity. 101 This rate apples if the beneficial owner is a company (excluding partnerships) which holds directly at least 25 per cent of the capital of the paying company.