Non-Resident Withholding Tax Rates for Treaty Countries

132 /

Country

Interest

Dividends

Royalties

Pensions/

Annuities

Algeria 15% 15% 0/15% 15/25%

Argentina

12.5 10/15 3/5/10/15 15/25

Armenia

10 5/15 10 15/25

Australia

10 5/15 10 15/25

Austria

10 5/15 0/10 25

Azerbaijan

10 10/15 5/10 25

Bangladesh

15 15 10 15/25

Barbados

15 15 0/10 15/25

Belgium

10 5/15 0/10 25

Brazil

15 15/25 15/25 25

Bulgaria

10 10/15 0/10 10/15/25

Cameroon

15 15 15 25

Chile

15 10/15 15 15/25

China, People’s Republic

10 10/15 10 25

Columbia

10 5/15 10 15/25

Croatia

10 5/15 10 10/15/25

Cyprus

15 15 0/10 15/25

Czech Republic

10 5/15 10 15/25

Denmark

10 5/15 0/10 25

Dominican Republic

18 18 0/18 18/25

Ecuador

15 5/15 10/15 15/25

Egypt

15 15 15 25

Estonia

10 5/15 10 10/15/25

Finland

10 5/15 0/10 15/20/25

Refer to notes on the following pages.

Current as of June 30, 2015

Non-Resident Withholding Tax Rates for Treaty Countries

Current as of June 30, 2015

The information contained herein is of a general nature and is not intended to address the

circumstances of any particular individual or entity. Although we endeavor to provide accurate and

timely information, there can be no guarantee that such information is accurate as of the date it is

received or that it will continue to be accurate in the future. No one should act on such information

without appropriate professional advice after a thorough examination of the particular situation.

2 | Non-Resident Withholding Tax Rates for Treaty Countries

Non-Resident Withholding Tax Rates for Treaty Countries / 133

Country

Interest

Dividends

Royalties

Pensions/

Annuities

France 10% 5/15% 0/10% 25%

Gabon 10 15 10 25

Germany 10 5/15 0/10 0/25

Greece 10 5/15 0/10 15/25

Guyana 15 15 10 25

Hong Kong 10 5/15 10 25

Hungary 10 5/15 0/10 10/15/25

Iceland 10 5/15 0/10 15/25

India 15 15/25 10/15/20 25

Indonesia 10 10/15 10 15/25

Ireland 10 5/15 0/10 0/15/25

Israel 15 15 0/15 15/25

Italy 10 5/15 0/5/10 15/25

Ivory Coast 15 15 10 15/25

Jamaica 15 15 10 15/25

Japan 10 5/15 10 25

Jordan 10 10/15 10 25

Kazakhstan

10 5/15 10 15/25

Kenya 15 15/25 15 15/25

Korea,

Republic of 10 5/15 10 10/15/25

Kuwait 10 5/15 10 15/25

Kyrgyzstan 15 15 0/10 15/25

Latvia

10 5/15 10 10/15/25

Lebanon

(10) (5/15) (5/10) (15/25)

Current as of June 30, 2015

The information contained herein is of a general nature and is not intended to address the

circumstances of any particular individual or entity. Although we endeavor to provide accurate and

timely information, there can be no guarantee that such information is accurate as of the date it is

received or that it will continue to be accurate in the future. No one should act on such information

without appropriate professional advice after a thorough examination of the particular situation.

3 | Non-Resident Withholding Tax Rates for Treaty Countries

134 /

Non-Resident Withholding Tax Rates for Treaty Countries

—Continued

Country

Interest

Dividends

Royalties

Pensions/

Annuities

Lithuania

10% 5/15% 10% 10/15/25%

Luxembourg 10 5/15 0/10 25

Malaysia 15 15 15 15/25

Malta 15 15 0/10 15/25

Mexico 10 5/15 0/10 15/25

Moldova 10 5/15 10 15/25

Mongolia 10 5/15 5/10 15/25

Morocco 15 15 5/10 25

Namibia

(10) (5/15) (0/10) (0/25)

Netherlands 10 5/15 0/10 15/25

New Zealand 10 5/15 5/10 0/15/25

Nigeria 12.5 12.5/15 12.5 25

Norway 10 5/15 0/10 15/25

Oman 10 5/15 0/10 15/25

Pakistan 15 15 0/15 25

Papua New Guinea 10 15 10 15/25

Peru

15 10/15 15 15/25

Philippines 15 15 10 25

Poland 10 5/15 5/10 15/25

Portugal 10 10/15 10 15/25

Romania 10 5/15 5/10 15/25

Russian Federation 10 10/15 0/10 0/25

Senegal 15 15 15 15/25

Refer to notes on the following pages.

Current as of June 30, 2015

The information contained herein is of a general nature and is not intended to address the

circumstances of any particular individual or entity. Although we endeavor to provide accurate and

timely information, there can be no guarantee that such information is accurate as of the date it is

received or that it will continue to be accurate in the future. No one should act on such information

without appropriate professional advice after a thorough examination of the particular situation.

4 | Non-Resident Withholding Tax Rates for Treaty Countries

Non-Resident Withholding Tax Rates for Treaty Countries / 135

Country

Interest

Dividends

Royalties

Pensions/

Annuities

Serbia 10% 5/15% 10% 15/25%

Singapore

15 15 15 25

Slovak Republic

10 5/15 0/10 15/25

Slovenia

10 5/15 10 0/10/15/25

South Africa

10 5/15 6/10 25

Spain

15 (10) 15 (5/15) 0/10 15/25

Sri Lanka

15 15 0/10 15/25

Sweden

10 5/15 0/10 25

Switzerland

10 5/15 0/10 15/25

Tanzania

15 20/25 20 15/25

Thailand

15 15 5/15 25

Trinidad & Tobago

10 5/15 0/10 15/25

Tunisia

15 15 0/15/20 25

Turkey

15 15/20 10 15/25

Ukraine

10 5/15 0/10 25

United Arab Emirates

10 5/15 0/10 25

United Kingdom

10 5/15 0/10 0/10/25

United States

0 5/15 0/10 15/25

Uzbekistan

10 5/15 5/10 25

Venezuela

10 10/15 5/10 25

Vietnam

10 5/10/15 7.5/10 15/25

Zambia

15 15 15 15/25

Zimbabwe

15 10/15 10 15/25

Current as of June 30, 2015

The information contained herein is of a general nature and is not intended to address the

circumstances of any particular individual or entity. Although we endeavor to provide accurate and

timely information, there can be no guarantee that such information is accurate as of the date it is

received or that it will continue to be accurate in the future. No one should act on such information

without appropriate professional advice after a thorough examination of the particular situation.

5 | Non-Resident Withholding Tax Rates for Treaty Countries

136 /

Non-Resident Withholding Tax Rates for Treaty Countries

Notes

(1) The actual treaty should be consulted to determine if speciﬁc conditions, exemptions or

tax-sparing provisions apply for each type of payment. The rates indicated in the table apply

to payments from Canada to the treaty country; in some cases, a treaty may provide for a

different rate of withholding tax on payments from the other country to Canada.

(2) As of June 30, 2015, Canada is negotiating or renegotiating tax treaties or protocols with

the following countries:

Australia Madagascar (new)

China (PRC) Malaysia

Israel Netherlands

(3) Canada imposes no domestic withholding tax on certain arm’s length interest payments,

however non-arm’s length payments are subject to a 25% withholding tax.

(4) Dividends subject to Canadian withholding tax include taxable dividends (other than capital

gains dividends paid by certain entities) and capital dividends.

The withholding tax rate on dividends under the terms of Canada’s tax treaties generally

varies depending on the percentage ownership of the total issued capital or voting rights

in respect of shares owned by the recipient.

(5) Royalties generally are deﬁned to include:

• Paymentsreceivedasconsiderationfortheuseofortherighttouseanycopyright,

patent, trademark, design or model, plan, secret formula or process.

• Paymentsreceivedasconsiderationfortheuseofortherighttouseindustrial,

commercial or scientiﬁc equipment or for information concerning industrial,

commercial or scientiﬁc experience.

• Paymentsinrespectofmotionpicturelms,andworksonlmorvideotapeforuse

in connection with television.

• Insomecases,technicalassistanceinrespectoftheseitemsisalsoincluded.

Canada generally exempts from withholding tax cultural royalties or similar payments

for copyrights in respect of the production or reproduction of any literary, dramatic,

musical or artistic work, other than motion-picture ﬁlms and videotapes or other means

of reproduction for use in connection with television. However, several treaties exempt all

cultural royalties from tax.

Canada announced in its treaty negotiations that it is prepared to eliminate the

withholding tax on arm’s-length payments in respect of rights to use patented information

or information concerning scientiﬁc experience. It also stated that it is prepared to

negotiate, on a bilateral basis, exemptions from withholding taxes for payments for the

use of computer software. As such, some recent treaties contain an exemption for such

payments.

Current as of June 30, 2015

The information contained herein is of a general nature and is not intended to address the

circumstances of any particular individual or entity. Although we endeavor to provide accurate and

timely information, there can be no guarantee that such information is accurate as of the date it is

received or that it will continue to be accurate in the future. No one should act on such information

without appropriate professional advice after a thorough examination of the particular situation.

6 | Non-Resident Withholding Tax Rates for Treaty Countries

Non-Resident Withholding Tax Rates for Treaty Countries / 137

(6) In general, the terms “pension,” “periodic pension payment” and “annuity” are deﬁned

in the applicable treaty. However, if they are deﬁned in the treaty by reference to the

laws of Canada, or are not speciﬁcally deﬁned therein, the deﬁnition in the Income Tax

Conventions Interpretation Act must be used.

Section 217 allows non-residents who earn certain types of pension and other retirement

beneﬁts to elect to ﬁle a Canadian tax return and pay Part I tax thereon, rather than being

subject to Canada’s 25% withholding tax on the income.

The withholding tax rate varies depending on, among other attributes, whether the

payment is a lump-sum or periodic payment, or if the payment is a pension or annuity.

Some treaties provide for an exemption for certain types of pensions or for an exemption

up to a threshold amount. Some pensions are taxable only in the source country.

(7) The treaty currently in effect with these countries includes a Most Favoured Nation clause,

which provides for reduced withholding rates if the other country signs a treaty with

another OECD member country and that treaty includes a lower withholding rate. This

clause allows the lower rate to apply to the Canadian treaty. The items of income to which

the clause applies vary by treaty. The lower withholding rate in the other country’s treaty

will apply to Canada if that treaty is signed after the date that Canada’s treaty with the

particular country is signed.

(8) A protocol or replacement treaty is signed but not yet ratiﬁed. If there are changes to

withholding tax rates in the protocol or replacement treaty, the new rates are indicated in

parentheses. Otherwise, the rates in the table continue to apply.

(9) A new treaty is signed but not yet in effect. The rates in the new treaty are indicated in

parentheses. Until ratiﬁcation, the withholding tax rate is generally 25%.

(10) The following terms apply under the provisions of the Canada-U.K. treaty, including the

protocol to amend the tax treaty which entered into force on December 18, 2014:

Interest—Interest is deﬁned as income from debt claims of every kind, whether or not

secured by mortgage, and whether or not carrying a right to participate in the debtor’s

proﬁts, including premiums and prizes attaching to bonds and debentures, as well as

income assimilated to income from money lent by the tax law of Canada or the U.K. as

the case may be. There are certain exemptions under the treaty. See also note (3).

Dividends—The 5% withholding tax rate applies if the recipient of the dividend is a

company that controls, directly or indirectly, at least 10% of the voting power of the payer.

The protocol introduces an exemption from withholding tax for certain dividends received

by organizations that operate exclusively to administer beneﬁts under recognized pension

plans. See also note (4).

Royalties—Cultural royalties, excluding royalties in respect of ﬁlms or motion pictures,

and videotapes or other media for use in television broadcasting, are taxable only in

the resident country. This treatment also applies to payments for the use of any patent

or for information concerning industrial, commercial or scientiﬁc experience, as well as

payments for the use of computer software. See also note (5).

Current as of June 30, 2015

The information contained herein is of a general nature and is not intended to address the

circumstances of any particular individual or entity. Although we endeavor to provide accurate and

timely information, there can be no guarantee that such information is accurate as of the date it is

received or that it will continue to be accurate in the future. No one should act on such information

without appropriate professional advice after a thorough examination of the particular situation.

7 | Non-Resident Withholding Tax Rates for Treaty Countries

138 /

Non-Resident Withholding Tax Rates for Treaty Countries

Notes, continued

Pensions/Annuities—Pensions are deﬁned to include any payment under a superannuation,

pension or retirement plan, and certain other amounts including payments made under

social security legislation. Periodic pension payments are taxable only in the resident

country.

Annuities are deﬁned as periodic payments payable during a person’s lifetime or for a

speciﬁed period of time, under an obligation to make the payments in return for money

or money’s worth. The deﬁnition excludes payments under pension or income averaging

annuity contracts. Annuities are subject to tax in the payer country at a rate of 10%. See

also note (6)

(11) The protocol to the Canada-U.S. treaty entered into force on December 15, 2008.

It introduced a number of provisions that do not exist in Canada’s other treaties.

• Treatybenetsapplytocertain“scallytransparententities”(FTEs)suchaslimited

liability companies, where the owner is resident in one of the countries, the income

oftheFTEissubjecttotaxintheowners’handsandtheFTEisnotresidentinthe

other country

• TreatybenetsaredeniedtocertainFTEsthataretreatedasow-throughentities

under the laws of one of the countries, and as regular taxable entities under the laws

of the other country

• ThepermanentestablishmentprovisionscovercertainCanadianorU.S.service

providers who are present in the other country for more than 183 days in any

12-month period

• The5%treatywithholdingtaxrateondividendsappliestocorporatemembersof

FTEsthatholdatleast10%ofthevotingsharesinthecompanypayingthedividends

• Thetreatyincludesalimitation-on-benets(LOB)clausethatgenerallyallowstreaty

benetstobeclaimedonlybycertain“qualifying”persons,orentitiescarryingon

connected active business activities in both countries.

The following items apply under the provisions of the Canada-U.S. treaty:

Interest—Interest is deﬁned as income from debt claims of every kind, whether or not

secured by mortgage, and whether or not carrying a right to participate in the debtor’s

proﬁts, including premiums and prizes attaching to bonds and debentures, as well as

income assimilated to income from money lent by the tax law of Canada or the U.S., as

thecasemaybe.ContingentinterestarisingintheU.S.thatdoesnotqualifyasportfolio

interest will be subject to a withholding rate of 15%. As well, interest arising in Canada

thatisdeterminedbyreferencetoreceipts,sales,income,protsorothercashowof

the debtor will also be subject to a 15% withholding rate. See also note (3).

Dividends—The 5% withholding tax rate applies if the recipient of the dividends is a

company that is the beneﬁcial owner of at least 10% of the voting stock of the payer. The

rate of Canadian branch tax is also limited to 5% on cumulative branch proﬁts exceeding

Cdn$500,000. The ﬁrst Cdn$500,000 of cumulative branch proﬁts are exempt from branch

tax. See also note (4).

Current as of June 30, 2015

©2015KPMGLLP,aCanadianlimitedliabilitypartnershipandamemberrmoftheKPMGnetworkofindependentmemberrms

afliatedwithKPMGInternationalCooperative(“KPMGInternational”),aSwissentity.Allrightsreserved

Current as of June 30, 2015

The information contained herein is of a general nature and is not intended to address the

circumstances of any particular individual or entity. Although we endeavor to provide accurate and

timely information, there can be no guarantee that such information is accurate as of the date it is

received or that it will continue to be accurate in the future. No one should act on such information

without appropriate professional advice after a thorough examination of the particular situation.

8 | Non-Resident Withholding Tax Rates for Treaty Countries

Non-Resident Withholding Tax Rates for Treaty Countries / 139

Royalties—Royalties are generally deﬁned as payments for the use of, or right to use, any

cultural property and any copyright of scientiﬁc work; any patent, trademark, design or

model, plan, secret formula or process; and information concerning industrial, commercial

or scientiﬁc experience. The deﬁnition also includes gains from the alienation of any

intangible property or rights in such property to the extent that such gains are contingent

on the productivity, use or subsequent disposition of such property or rights. See also

note (5).

The following royalties are exempt from withholding tax:

• Culturalroyalties,excludingroyaltiesinrespectoflmsormotionpictures,and

videotapes or other media for use in television broadcasting

• Paymentsfortheuseof,orrighttouse,computersoftware

• Paymentsfortheuseof,orrighttouse,patentsorinformationconcerningindustrial,

commercial or scientiﬁc experience (excluding any such information in relation to a

rental or franchise agreement)

• Paymentsinrespectofbroadcastingasmaybeagreedtobetweenthecountries.

Pensions/Annuities—Pensionsaredenedtoincludeanypaymentunderasuperannuation,

pension, or other retirement arrangement and certain other amounts, but exclude income

averagingannuitycontractpayments.ThedenitionofpensionsalsoincludesRothIRAs

andsimilararrangements.PaymentsofOldAgeSecurityandCanada/QuebecPension

PlanbenetstoU.S.residentsaretaxableonlyintheU.S.andarenotsubjecttoCanadian

withholdingtax.TheU.S.doesnotwithholdtaxonsocialsecuritybenetspaidto

Canadianresidents,andonly85%ofsuchbenetsaretaxablebyCanada.

Annuitiesaredenedasperiodicpaymentspayableduringaperson’slifetimeorfora

speciﬁed period of time, under an obligation to make the payments in return for adequate

and full consideration (other than services rendered). The deﬁnition excludes non-periodic

payments or any annuity the cost of which was tax deductible in the country in which it

was acquired. See also note (6).

CurrentasofJune30,2015

©2015KPMGLLP,aCanadianlimitedliabilitypartnershipandamemberrmoftheKPMGnetworkofindependentmemberrms

afliatedwithKPMGInternationalCooperative(“KPMGInternational”),aSwissentity.Allrightsreserved.

Current as of June 30, 2015

The information contained herein is of a general nature and is not intended to address the

circumstances of any particular individual or entity. Although we endeavor to provide accurate and

timely information, there can be no guarantee that such information is accurate as of the date it is

received or that it will continue to be accurate in the future. No one should act on such information

without appropriate professional advice after a thorough examination of the particular situation.