As a result of the 2017 tax reform, a new WHT on dividend distributions and branch profit remittances has been introduced at a rate of 7% (while the applicable profits tax rate is at 30%) and 13% (when the profits tax rate lowers to 25%).
The tax reform also has abolished the so-called ‘equalisation tax’ for profits generated in taxable years starting on or after 1 January 2018. The equalisation tax was a WHT levied at a 35% rate on dividend distributions in excess of tax earnings. However, the equalisation tax still applies to dividend and branch profit distributions made out of earnings accumulated prior to 1 January 2018 that exceeded tax earnings as of the year-end prior to the relevant distribution.
Other payments to residents and to non-residents are subject to WHT rates as follows:
Several other concepts of 'royalties' are subject to rates that, in turn, may be limited by treaty. A broad sample of these concepts and the non-treaty effective rates are set forth in Note 2.
Last Reviewed - 31 July 2018