List of published territories Afghanistan, Islamic Republic of$$$Albania$$$Algeria$$$Angola$$$Antigua and Barbuda$$$Argentina$$$Armenia$$$Aruba$$$Australia$$$Austria$$$Azerbaijan$$$Bahrain$$$Barbados$$$Belarus$$$Belgium$$$Bermuda$$$Bolivia$$$Bosnia and Herzegovina$$$Botswana$$$Brazil$$$Bulgaria$$$Cabo Verde$$$Cambodia$$$Cameroon, Republic of$$$Canada$$$Caribbean Netherlands$$$Cayman Islands$$$Chad$$$Chile$$$China, People's Republic of$$$Colombia$$$Congo, Democratic Republic of the$$$Congo, Republic of$$$Costa Rica$$$Croatia$$$Curaçao$$$Cyprus$$$Czech Republic$$$Denmark$$$Dominica , Commonwealth of$$$Dominican Republic$$$Ecuador$$$Egypt$$$El Salvador$$$Equatorial Guinea$$$Estonia$$$Fiji$$$Finland$$$France$$$Gabon$$$Georgia$$$Germany$$$Ghana$$$Gibraltar$$$Greece$$$Greenland$$$Guatemala$$$Guernsey, Channel Islands$$$Guyana$$$Honduras$$$Hong Kong$$$Hungary$$$Iceland$$$India$$$Indonesia$$$Iraq$$$Ireland$$$Isle of Man$$$Israel$$$Italy$$$Ivory Coast (Côte d'Ivoire)$$$Jamaica$$$Japan$$$Jersey, Channel Islands$$$Jordan$$$Kazakhstan$$$Kenya$$$Korea, Republic of$$$Kosovo$$$Kuwait$$$Kyrgyzstan$$$Lao PDR$$$Latvia$$$Lebanon$$$Libya$$$Liechtenstein$$$Lithuania$$$Luxembourg$$$Macau$$$Macedonia$$$Madagascar$$$Malawi$$$Malaysia$$$Malta$$$Mauritius$$$Mexico$$$Moldova$$$Mongolia$$$Montenegro$$$Morocco$$$Mozambique$$$Myanmar$$$Namibia, Republic of$$$Netherlands$$$New Zealand$$$Nicaragua$$$Nigeria$$$Norway$$$Oman$$$Pakistan$$$Panama$$$Papua New Guinea$$$Paraguay$$$Peru$$$Philippines$$$Poland$$$Portugal$$$Puerto Rico$$$Qatar$$$Romania$$$Russian Federation$$$Rwanda$$$Saint Kitts and Nevis$$$Saint Lucia$$$Saudi Arabia$$$Senegal$$$Serbia$$$Singapore$$$Sint Maarten$$$Slovak Republic$$$Slovenia$$$South Africa$$$Spain$$$Sri Lanka$$$Swaziland$$$Sweden$$$Switzerland$$$Taiwan$$$Tajikistan$$$Tanzania$$$Thailand$$$Timor-Leste$$$Trinidad and Tobago$$$Tunisia$$$Turkey$$$Turkmenistan$$$Uganda$$$Ukraine$$$United Arab Emirates$$$United Kingdom$$$United States$$$Uruguay$$$Uzbekistan, Republic of$$$Venezuela$$$Vietnam$$$Zambia$$$Zimbabwe JDCN-ANSNYN$$$JDCN-89JRLJ$$$JDCN-9L9ER3$$$JDCN-89HREB$$$JDCN-89HRFR$$$JDCN-89HRGN$$$JDCN-89HRHB$$$JDCN-89HRHY$$$JDCN-89HRJM$$$JDCN-89HRKA$$$JDCN-89HRKX$$$JDCN-89HRLL$$$JDCN-89HRM9$$$JDCN-89HRMW$$$JDCN-89HRNK$$$JDCN-89HRP8$$$JDCN-89HRPV$$$JDCN-89HRQJ$$$JDCN-89HRR7$$$JDCN-89HRRU$$$JDCN-89HRSH$$$JDCN-89HRV5$$$JDCN-89HRT6$$$JDCN-89HRTT$$$JDCN-89HRUG$$$JDCN-8FWH76$$$JDCN-89HRVS$$$JDCN-89HRWF$$$JDCN-89HRYE$$$JDCN-89HRZ3$$$JDCN-89HRZQ$$$JDCN-89HS2D$$$JDCN-89HS32$$$JDCN-89HS3P$$$JDCN-89PKJ7$$$JDCN-89HTBS$$$JDCN-89HS5N$$$JDCN-89HS6B$$$JDCN-89HS6Y$$$JDCN-8V8FHF$$$JDCN-89HS7M$$$JDCN-89HS8A$$$JDCN-89HS8X$$$JDCN-89HS9L$$$JDCN-89HSA9$$$JDCN-89HSAW$$$JDCN-89HSBK$$$JDCN-89HSC8$$$JDCN-89HSCV$$$JDCN-89HSDJ$$$JDCN-89HSE7$$$JDCN-89HSEU$$$JDCN-89HSFH$$$JDCN-89HSG6$$$JDCN-89HSGT$$$JDCN-9LFTHK$$$JDCN-89HSHG$$$JDCN-89HRX4$$$JDCN-8UENHH$$$JDCN-89HSJ5$$$JDCN-89HSJS$$$JDCN-89HSKF$$$JDCN-8HLNAZ$$$JDCN-89HSL4$$$JDCN-89HSLR$$$JDCN-89HSME$$$JDCN-89HSN3$$$JDCN-89HSNQ$$$JDCN-89HSPD$$$JDCN-89HSQ2$$$JDCN-89HSQP$$$JDCN-89HSRC$$$JDCN-89HSRZ$$$JDCN-89HRXR$$$JDCN-89HSSN$$$JDCN-89HSTB$$$JDCN-89HSTY$$$JDCN-89HSUM$$$JDCN-AN9ENE$$$JDCN-89HSVA$$$JDCN-89HSVX$$$JDCN-8EGQEM$$$JDCN-89HSWL$$$JDCN-89HSX9$$$JDCN-89HSXW$$$JDCN-89HSYK$$$JDCN-89HSZ8$$$JDCN-89HSZV$$$JDCN-89HT2J$$$JDCN-89HT38$$$JDCN-89HT3V$$$JDCN-89HT4J$$$UKWE-8CEb2F$$$JDCN-89HT5U$$$JDCN-89HT6H$$$JDCN-89HT77$$$JDCN-89HT7U$$$JDCN-89HT8H$$$JDCN-89HT96$$$JDCN-8HLRL5$$$JDCN-89HT9T$$$JDCN-97XLRC$$$JDCN-89HTAG$$$JDCN-89HTB5$$$JDCN-89HTCF$$$JDCN-89HTD4$$$JDCN-89HTDR$$$JDCN-89HTEE$$$JDCN-89HTF3$$$JDCN-89HTFR$$$JDCN-89HTGE$$$JDCN-89HTH3$$$JDCN-89HTHQ$$$JDCN-89HTJD$$$JDCN-89HTK2$$$JDCN-89HTKP$$$JDCN-89HTLC$$$JDCN-89HTLZ$$$JDCN-89HTMN$$$JDCN-89HTNB$$$JDCN-89HTNY$$$JDCN-8UPFL5$$$JDCN-89HTVJ$$$JDCN-89HTW7$$$JDCN-89HTPM$$$JDCN-89HTQA$$$JDCN-89HTQX$$$JDCN-89HTRL$$$JDCN-8FWGMB$$$JDCN-89HTS9$$$JDCN-89HTSW$$$JDCN-89HTTK$$$UKWE-8CDMS7$$$JDCN-89HTUV$$$JDCN-89HTWU$$$JDCN-89HTXH$$$JDCN-89HTY6$$$JDCN-89HTZG$$$JDCN-89HU25$$$JDCN-89HU2S$$$JDCN-89HU3F$$$JDCN-8VDJC3$$$JDCN-89HU44$$$JDCN-8V8FQH$$$JDCN-89HU4R$$$JDCN-89HU5E$$$JDCN-89HU63$$$JDCN-89HU6Q$$$JDCN-89HU7D$$$JDCN-89HU82$$$JDCN-89HU8P$$$JDCN-89HU9C$$$JDCN-89HU9Z$$$JDCN-89HUAN$$$JDCN-89HUBB$$$JDCN-9LFTHP$$$JDCN-89HUBY Afghanistan$$$Barbuda$$$Herzegovina$$$Cape Verde$$$Republic of Cameroon$$$People's Republic of China$$$Peoples Republic of China$$$Democratic Republic of the Congo$$$DRC$$$Republic of Congo$$$Curacao$$$Commonwealth of Dominica$$$Channel Islands$$$Channel Islands$$$South Korea$$$Republic of Korea$$$Laos$$$Republic of Lebanon$$$The Netherlands$$$PNG$$$Russia$$$Nevis$$$St. Kitts and Nevis$$$St Kitts and Nevis$$$St. Lucia$$$St Lucia$$$St. Maarten$$$St Maarten$$$Slovakia$$$SA$$$Tobago$$$Republic of Turkey$$$UAE$$$Great Britain$$$UK$$$Britain$$$Whales$$$Northern Ireland$$$England$$$US$$$U.S.$$$U.S.A.$$$USA$$$Republic of Uruguay$$$Republic of Uzbekistan$$$Republic of Zambia

Israel Corporate - Withholding taxes

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Under Israeli domestic tax law, WHT on payments of Israeli-source income is generally deducted at the corporate tax rate from all income remittances abroad, unless a tax certificate is obtained from the ITA authorising withholding-exempt remittances or a reduced rate of tax pursuant to an applicable tax treaty.

Set out below is a listing of WHT rates for dividends, interest, and royalties under domestic tax law and pursuant to tax treaties in force. Detailed rules apply under certain tax treaties for eligibility to the treaty-reduced rates (e.g. beneficial ownership, having no PE in Israel). The applicable tax treaty should be consulted to determine the relevant WHT rate and to examine detailed conditions that may apply for the specific circumstance.

Recipient Dividends (%) Interest * (%) Royalties (%)
Resident corporations 0/24 (1) 24 30
Resident individuals 25/30 (1, 2) 25 (32) 30
Non-resident corporations:      
Non-treaty 25/30 (2) 24 24
Treaty:      
Austria 25 15 0/10 (49)
Belarus 10 5/10 (33) 5/10 (50)
Belgium 15 15 0/10 (51)
Brazil 10/15 (3) 15 10/15 (52)
Bulgaria 10/12.5 (4) 5/10 (34) 12.5 (53)
Canada 5/15 (54) 5/10 (54) 0/10 (54)
China, People’s Republic of 10 7/10 (35) 10 (55)
Croatia 5/10/15 (5) 5/10 (36) 5
Czech Republic 5/15 (6) 10 5
Denmark 0/10 (73) 5 (74) 0
Estonia 0/5 (7) 5 0
Ethiopia 5/10/15 (8) 5/10 (37) 5
Finland 5/15 (9) 10 10
France 5/10/15 (10) 5/10 (38) 0/10 (56)
Georgia 0/5 (71) 0/5 (72) 0
Germany 5/10 (57) 0/5 (57) 0 (57)
Greece 25 (11) 10 10
Hungary 5/15 (12) 0 0
India 10 10 10
Ireland, Republic of 10 5/10 (39) 10
Italy 10/15 (13) 10 0/10 (58)
Jamaica 15/22.5 (14) 15 10
Japan 5/15 (15) 10 10
Korea, Republic of 5/10/15 (16) 7.5/10 (40) 2/5 (59)
Latvia 5/10/15 (17) 5/10 (41) 5
Lithuania 5/10/15 (17) 10 5/10 (60)
Luxembourg 5/10/15 (18) 5/10 (41) 5
Macedonia - not yet ratified (78) 5/15 (78) 10 5
Malta 0/15 (75) 5 0
Mexico 5/10 (19) 10 10
Moldova 5/10 (20) 5 5
Netherlands 5/10/15 (21) 10/15 (42) 5/10 (61)
Norway 25 25 10
Panama 5/15/20 (76) 15 (77) 15
Philippines 10/15 (22) 10 15
Poland 5/10 (23) 5 5/10 (62)
Portugal 5/10/15 (24) 10 10
Romania 15 5/10 (43) 10
Russia 10 10 10
Singapore 5/10 (25) 7 5
Slovakia 5/10 (26) 2/5/10 (44) 5
Slovenia 5/10/15 (27) 5 5
South Africa 25 25 0 (63)
Spain 10 5/10 (45) 5/7 (64)
Sweden 0 25 0 (65)
Switzerland 5/10/15 (28) 5/10 (37) 5
Taiwan (Republic of China) 10 7/10 (46) 10
Thailand 10/15 (29) 10/15 (47) 5/15 (66)
Turkey 10 10 10
Ukraine 5/10/15 (30) 5/10 (37) 10
United Kingdom 15 15 0 (67)
United States 12.5/25 (31) 10/17.5 (48) 10/15 (68)
Uzbekistan 10 10 5/10 (69)
Vietnam 10 10 5/7.5/15 (70)

Notes

* Some Israeli tax treaties provide for an exemption from WHT on interest involving governmental and quasi-governmental parties. Such exemptions are not separately indicated in the table above.

  1. Dividends between Israeli resident companies are generally exempt from Israeli tax. Dividends paid from a foreign resident company received via an Israeli payer (e.g. bank) are subject to WHT at the rate of 24% when paid to an Israeli resident company and at the rate of 25% when paid to an individual.
  2. 30% rate applies in the case of a ‘substantial shareholder’, which is, in general, a shareholder that holds 10% or more of the rights of the company (detailed rules apply).
  3. 10% where beneficial owner directly holds at least 25% of the capital of the company paying the dividends.
  4. At a rate that is 50% of the rate that would have been imposed but for this provision but not to exceed 12.5% and not less than 7.5%. A 10% rate applies where paid from profits generated by an enterprise entitled to special tax rates under the Encouragement of Investment Law.
  5. 5% if the beneficial owner is a company (other than a partnership) that directly holds at least 25% of the capital of the company paying the dividends; 10% rate if the beneficial owner is a company that directly holds at least 10% of the capital of the company paying the dividends where that latter company is a resident of Israel and the dividends are paid out of profits that are subject to tax in Israel at a rate that is lower than the normal rate of Israeli corporate tax; 15% rate applies in all other cases.
  6. 5% if the beneficial owner is a company (other than a partnership) that directly holds at least 15% of the capital of the company paying the dividends; 15% rate in all other cases.
  7. 0% if the beneficial owner is a company (other than a partnership) that directly holds at least 10% of the capital of the company paying the dividends; 5% rate in all other cases.
  8. 5% if the beneficial owner is a company (other than a partnership) that directly holds at least 10% of the capital of the company paying the dividends; 10% rate if the beneficial owner is a company that directly holds at least 10% of the capital of the company paying the dividends where that latter company is a resident of Israel and the dividends are paid out of profits that are subject to tax in Israel at a rate that is lower than the normal rate of Israeli corporate tax; 15% rate in all other cases.
  9. 5% if the beneficial owner is a company (other than a partnership) that directly controls at least 10% of the voting power in the company paying the dividends; 15% rate in all other cases.
  10. 5% if the beneficial owner is a company that directly or indirectly holds at least 10% of the capital of the company paying the dividends; 10% rate if the beneficial owner is a company that directly or indirectly holds at least 10% of the capital of the company paying the dividends and the dividends are paid out of profits that are subject to tax in Israel at a rate that is lower than the normal rate of Israeli corporate tax; 15% rate in all other cases.
  11. At the domestic Israeli tax rate.
  12. 5% if the recipient directly holds at least 10% of the capital of the company paying the dividends.
  13. 10% if the beneficial owner is a company (other than a partnership) that directly holds at least 25% of the capital of the company paying the dividends.
  14. 15% if the beneficial owner is a company (other than a partnership) that directly or indirectly holds at least 10% of the voting power of the company paying the dividends.
  15. 5% if the beneficial owner is a company that owns at least 25% of the voting shares of the company paying the dividends during the period of six months immediately before the end of the accounting period for which the distribution of profits takes place.
  16. 5% if the beneficial owner is a company that directly or indirectly holds at least 10% of the capital of the company paying the dividends; 10% rate if the beneficial owner is a company that holds 10% of the capital of the company paying the dividends and the dividends are paid out of profits that are subject to tax at a rate that is lower than the normal rate of the corporation tax; 15% rate in all other cases.
  17. 5% if the beneficial owner is a company (other than a partnership) that directly holds at least 10% of the capital of the company paying the dividends; 10% rate if the beneficial owner is a company that directly holds at least 10% of the capital of the company paying the dividends where the dividends are paid out of profits that by virtue of provisions in the Israeli Law of Encouragement of Investments in Israel are exempt from tax or subject to tax at a rate that is lower than the normal rate of Israeli corporate tax; 15% rate in all other cases.
  18. 5% if the beneficial owner is a company (other than a partnership) that directly holds at least 10% of the capital of the company paying the dividends; 10% rate if the beneficial owner is a company that directly holds at least 10% of the capital of the company paying the dividends and the dividends are paid out of profits that are subject to tax in Israel at a rate that is lower than the normal rate of Israeli corporate tax; 15% rate in all other cases.
  19. 5% if the beneficial owner is a company that directly or indirectly holds at least 10% of the capital of the company paying the dividends.
  20. 5% if the beneficial owner is a company (other than a partnership) that directly holds at least 25% of the capital of the company paying the dividends.
  21. With respect to dividends paid to a company that directly holds at least 25% of the capital of the company paying the dividends: (i) 10% where the dividends are paid out of profits that, by virtue of provisions in Israeli law for the encouragement of investment in Israel, are exempted from tax or subject to tax at a rate that is lower than the standard rate levied on the profits of a company resident in Israel; (ii) 5% where paid out of regularly taxed profits. A 15% rate applies in all other cases.
  22. 10% if the beneficial owner is a company (excluding partnership) that directly holds at least 10% of the capital of the paying company.
  23. 5% if the recipient directly holds at least 15% of the capital of the company paying dividends.
  24. 5% if the beneficial owner is a company (other than a partnership) that directly holds at least 25% of the capital of the company paying the dividends; 10% rate if the beneficial owner is a company that directly holds at least 25% of the capital of the company paying the dividends where that latter company is a resident of Israel and the dividends are paid out of profits that are subject to tax in Israel at a rate that is lower than the normal rate of Israeli corporate tax; 15% rate in all other cases.
  25. 5% if the beneficial owner directly holds at least 10% of the capital of the company paying the dividends.
  26. 5% if the recipient directly or indirectly holds at least 10% of the capital of the company paying the dividends.
  27. 5% of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) that directly holds at least 10% of the capital of the company paying the dividends; 10% of the gross amount of the dividends if the beneficial owner is a company that directly holds at least 10% of the capital of the company paying the dividends and the dividends are paid out of profits that, by virtue of law of the state in which the payer is a resident, are exempt from corporate tax or subject to corporate tax at a rate that is lower than the normal rate in that state; 15% of the gross amount of the dividends in all other cases.
  28. 5% if the beneficial owner is a company (other than a partnership) that directly holds at least 10% of the capital of the company paying the dividends; 10% rate if the beneficial owner is a company that directly holds at least 10% of the capital of the company paying the dividends where that latter company is a resident of Israel and the dividends are paid out of profits that are subject to tax in Israel at a rate that is lower than the normal rate of Israeli corporate tax; 15% rate in all other cases.
  29. 10% if the recipient holds at least 25% of the capital of the company paying the dividends.
  30. 5% if the beneficial owner is a company (other than a partnership) that directly holds at least 25% of the capital of the company paying the dividends; 10% if the beneficial owner is a company that directly holds at least 10% of the capital of the company paying the dividends where that latter company is a resident of Israel and the dividends are paid out of profits that are subject to tax in Israel at a rate that is lower than the normal rate of Israeli corporate tax; 15% in all other cases.
  31. 12.5% but only if (i) during the part of the paying corporation's taxable year that precedes the date of payment of the dividend and during the whole of its prior taxable year (if any), at least 10% of the outstanding shares of the voting stock of the paying corporation was owned by the recipient corporation, and (ii) not more than 25% of the gross income of the paying corporation for such prior taxable year (if any) consists of interest or dividends (other than interest derived from the conduct of a banking, insurance, or financing business and dividends or interest received from subsidiary corporations, 50% or more of the outstanding shares of the voting stock of which is owned by the paying corporation at the time such dividends or interest is received). A 15% rate applies for payments from income derived during any period for which the paying corporation is entitled to the reduced tax rate applicable to an AE under Israel's Encouragement of Capital Investments Law (1959). A 25% rate applies in all other cases.
  32. WHT is generally at a rate of 15% if the loan/interest is not linked to any index. Interest paid on a bond to a shareholder who holds less than 10% of the rights of the company is generally taxed at a rate of 35%. A WHT rate of 47% applies in the case of a substantial shareholder (in general, a shareholder that holds 10% or more of rights of the company). An additional tax at a rate of 3% applies on an individual's income if their income from all sources in a tax year exceeds ILS 640,000 (in 2017). Detailed rules apply.
  33. 5% for interest in connection with the sale on credit of any industrial, commercial, or scientific equipment or on any loan of whatever kind granted by a bank.
  34. 5% for interest in the case of a bank or other financial institution.
  35. 7% for interest received by any bank or financial institution.
  36. 5% for interest paid on a loan granted by a bank.
  37. 5% for interest paid on any loan of whatever kind granted by a bank.
  38. 5% where in connection with the sale on credit of any industrial, commercial, or scientific equipment, or sale on credit of any merchandise by one enterprise to another enterprise, or on any loan of whatever kind granted by a bank loans made by banks; 10% in all other cases. An election can be made to be taxed on the net amount of the interest as if such interest were business profits.
  39. 5% for interest paid in connection with the sale on credit of any industrial, commercial, or scientific equipment, sale on credit of any merchandise by one enterprise to another enterprise, or on any loan of whatever kind granted by a bank.
  40. 7.5% for interest if received by any bank or financial institution.
  41. 5% where paid on any loan of whatever kind granted by a bank.
  42. 10% where paid to a bank or a financial institution.
  43. 5% where paid in connection with the sale on credit of any industrial, commercial, or scientific equipment, or sale on credit of any merchandise by one enterprise to another enterprise, or on any loan of whatever kind granted by a bank.
  44. 2% applies to government debt or government-assisted debt; 5% rate applies when paid to a financial institution; 10% rate applies in all other cases.
  45. 5% in connection with the sale on credit of any industrial, commercial, or scientific equipment, or in connection with the sale on credit of any merchandise by one enterprise to another enterprise, or on any loan granted by a financial institution.
  46. 7% for interest paid on any loan of whatever kind granted by a bank.
  47. 10% for interest received by any financial institution (including an insurance company).
  48. 10% for interest derived from a loan of whatever kind granted by a bank, savings institution, or insurance company or the like. 17.5% rate for other interest. An election may be made to be taxed on interest income as if that income were industrial and commercial profits.
  49. 0% for literary, dramatic, musical, or artistic work copyright royalties (excluding in respect of motion picture films or films for use in connection with television).
  50. 5% for copyright royalties for literary, artistic, or scientific work (excluding cinematograph films) or for the use of, or the right to use, industrial, commercial, or scientific equipment or road-transport vehicles.
  51. 0% for copyright royalties for literary, dramatic, musical, artistic, or scientific work (excluding in respect of films for cinema or television).
  52. 15% for trademark royalties.
  53. The rate is 50% of the rate that would have been imposed but for the treaty provision but not to exceed 12.5% and not to be less than 7.5%.
  54. A new tax convention between Canada and the State of Israel is effective as of 1 January 2017 (in force since 21 December 2016). The new tax convention replaces the convention signed on 21 July 1975. Under the new tax convention, the following rates apply:
    • Dividends: The rate is 5% of the gross amount of dividends if the beneficial owner of the dividends is a company (other than a partnership) that directly holds at least 25% of the capital of the company paying the dividends; in all other cases, the rate is 15% of the gross amount of the dividends.
    • Interest: The rate is 5% of the gross amount of interest if the beneficial owner of the interest is a financial institution and is dealing at arm's length with the payer; in all other cases, the rate is 10% of the gross amount of the interest.
    • Royalties: The rate is 10% of the gross amount of the royalties; 0% for copyright royalties for and other like payments in respect of the production or reproduction of any literary, dramatic, musical, or artistic work (excluding royalties in respect of motion picture films and royalties in respect of works on film, videotape, or other means of reproduction for use in connection with television broadcasting); and 0% for royalties for the use of, or the right to use, computer software or any patent or for information concerning industrial, commercial, or scientific experience (but not including any such royalty provided in connection with a rental or franchise agreement).
  55. For industrial, commercial, and scientific equipment royalties, the 10% rate applies to the adjusted amount of the royalties (70% of the gross amount of the royalties).
  56. 0% for copyright royalties for literary, artistic or scientific work (excluding cinematograph films).
  57. A new tax treaty between Israel and Germany is effective as of 1 January 2017 (in force since 9 May 2016). The new tax treaty replaces the treaty signed on 9 July 1962. Under the new tax treaty, the following rates apply:
    • Dividends will be taxable at a maximum rate of 5% if the beneficial owner is a company that directly holds at least 10% of the capital of the payer company; a 10% rate will apply in all other cases.
    • Interest will be taxable at a maximum rate of 5% and will be exempt in certain circumstances.
    • Royalties will be taxable only in the beneficial owner's state of residence.
  58. 0% for copyright royalties for literary, artistic, or scientific work (excluding cinematograph films or tapes for television or broadcasting).
  59. 2% for industrial, commercial, and scientific equipment royalties.
  60. 5% for industrial, commercial, and scientific equipment royalties.
  61. 10% for royalties for cinematograph films and films or video-tapes for radio or television broadcasting.
  62. 5% for industrial, commercial, or scientific equipment royalties.
  63. For royalties in respect of cinematograph or television films, the WHT rate shall not exceed tax at the rate applicable to companies on 15% of the gross amount of the royalty.
  64. 5% for royalties for copyrights of literary, dramatic, musical, artistic work, or for the use of, or the right to use, industrial, commercial, or scientific equipment.
  65. The definition of royalties does not include any royalty or other amount paid in respect of (i) the operation of a mine or quarry or of any other extraction of natural resources or (ii) in respect of cinematograph including television films.
  66. 5% for royalties for literary, artistic, or scientific work, excluding cinematograph films or films or tapes used for radio, or television broadcasting.
  67. For royalties in respect of cinematograph or television films, tax may be imposed in Israel, but not to exceed tax at the rate applicable to companies on 15% of the gross amount of the royalty.
  68. 10% for copyright or film royalties.
  69. 5% of the gross amount of the royalties where such royalties consist of payments of any kind received as a consideration for the use or the right to use any copyright of literary, artistic, or scientific work (excluding cinematograph films).
  70. 5% for royalties for any patent, design or model, plan, secret formula, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial, or scientific experience; 7.5% for technical fees; 15% for all other royalties.
  71. 0% if the beneficial owner is a company (other than a partnership) that directly holds at least 10% of the capital of the company paying the dividends or where paid to certain qualifying pension funds.
  72. 0% if to a pension fund or if paid on publicly traded corporate bonds or in respect of a loan, debt-claim, or credit guaranteed or insured by an institution for insurance or financing of international trade transactions that is wholly owned by Israel.
  73. 0% if the beneficial owner is a company (other than a partnership) that directly holds at least 10% of the capital of the company paying the dividends where such holding is being possessed for an uninterrupted period of no less than one year and the dividends are declared within that period; or if the beneficial owner is the other contracting state or a central bank of that other state, or any other national agency or any other agency (including a financial institution) owned or controlled by the government of that other state; or where paid to certain qualifying pension funds. 10% in all other cases.
  74. A resident of a contracting state may elect, in lieu of the tax that would be imposed, to make an election to be taxed on the interest income as if that income were business profits.
  75. 0% if the beneficial owner is a company that directly holds at least 10% of the capital of the company paying the dividends; 15% in all other cases.
  76. 5% if the beneficial owner is a pension fund; 20% if the distributing company is a real estate investment company and the beneficial owner owns less than 10% of the capital of the company paying the dividends; 15% for all other dividends.
  77. 0% if to a pension fund or if paid on publicly traded corporate bonds or if the company paying the funds or the beneficial owner is one of the contracting states or one of their central banks, political subdivisions, or local authorities.
  78. An Income Tax Convention and Final Protocol between Israel and Macedonia was signed on 9 December 2015, and is still pending. Once ratified, the following WHT rates in relation to dividends shall apply: 5% of the gross amount of the dividends if the beneficial owner of the dividends is a company (other than a partnership or a real estate investment company) that directly holds at least 25% of the capital of the company paying the dividends; and 15% of the gross amount of the dividends in all other cases.

Last Reviewed - 01 December 2017

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