September 17, 2021
3. Maritime and air transport The new DTT has added a subsection subsection, under the item navigation and air transport, to define the extent of the benefits derived from shipping and air transport. 4. Related companies The “Associated Enterprises” clause aims to address transfer pricing (“TP”) issues. In other words, the adjustment of taxable profits made by a contracting country for reasons of compensation is allowed. The new DTT outweighs the fact that, in this case, the other country is taking the lead in an appropriate fiscal adjustment in the opposite direction. Dividends According to the old T&D, dividends can be taxed in the country of origin and the tax collected by the country of origin cannot exceed 10% of the gross dividend. The new DTT lowered the tax rate to 5% when the dividend recipient (as a resident of the company) directly holds 25% or more shares in the dividend company. Otherwise, the tax rate will remain at 10%.
It should be noted that the 5% tax rate does not apply to a partnership or similar company, even though it may hold more than 25% of the capital in the company that pays dividends. The new DTT also addresses the issue of dividends paid by an investment instrument (e.g..B Real Estate Investment Trusts) for which profits (from which dividends are paid) come from real estate. In certain circumstances, the beneficiary of the dividends cannot be protected by the tax rate of 10% or 5% for dividends from the investment instrument. Interest As with the former DTT, the rate of income tax levied by the starting company on savings income is limited to 10%. Tax legislation is adopted by the home country for interest paid to the other government (2) for loans guaranteed or guaranteed by the government of the other state or by financial institutions wholly owned by the other state, (3) certain financial institutions specifically mentioned in the DTT. The new DTT added a subsection under this clause stipulating that the country of origin does not have the tax legislation on interest earned on deferred payments related to the purchase of commercial and scientific equipment. 7. Fees The tax levied by the country of origin for royalties remains limited to 10% of the gross amount. However, for the rental of equipment, the effective tax rate will be reduced from 7% to 6%. 8.
Capital gains According to the former DTT, capital gains from the transfer of shares from the country of origin may be taxed. . . .
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