List of published territories Albania$$$Algeria$$$Angola$$$Argentina$$$Armenia$$$Australia$$$Austria$$$Azerbaijan$$$Bahrain$$$Barbados$$$Belarus$$$Belgium$$$Bermuda$$$Bolivia$$$Bosnia and Herzegovina$$$Botswana$$$Brazil$$$Bulgaria$$$Cabo Verde$$$Cambodia$$$Cameroon, Republic of$$$Canada$$$Cayman Islands$$$Chad$$$Chile$$$China, People's Republic of$$$Colombia$$$Congo, Democratic Republic of the$$$Congo, Republic of$$$Costa Rica$$$Croatia$$$Cyprus$$$Czech Republic$$$Denmark$$$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$$$Pakistan$$$Palestinian territories$$$Panama$$$Papua New Guinea$$$Paraguay$$$Peru$$$Philippines$$$Poland$$$Portugal$$$Puerto Rico$$$Qatar$$$Romania$$$Russian Federation$$$Rwanda$$$Saint Lucia$$$Saudi Arabia$$$Senegal$$$Serbia$$$Singapore$$$Slovak Republic$$$Slovenia$$$South Africa$$$Spain$$$Sri Lanka$$$Swaziland$$$Sweden$$$Switzerland$$$Taiwan$$$Tajikistan$$$Tanzania$$$Thailand$$$Timor-Leste$$$Trinidad and Tobago$$$Tunisia$$$Turkey$$$Turkmenistan$$$Turks and Caicos Islands$$$Uganda$$$Ukraine$$$United Arab Emirates$$$United Kingdom$$$United States$$$Uruguay$$$Uzbekistan, Republic of$$$Venezuela$$$Vietnam$$$Zambia$$$Zimbabwe JDCN-89JRLJ$$$JDCN-9L9ER3$$$JDCN-89HREB$$$JDCN-89HRGN$$$JDCN-89HRHB$$$JDCN-89HRJM$$$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-89HRVS$$$JDCN-89HRWF$$$JDCN-89HRYE$$$JDCN-89HRZ3$$$JDCN-89HRZQ$$$JDCN-89HS2D$$$JDCN-89HS32$$$JDCN-89HS3P$$$JDCN-89PKJ7$$$JDCN-89HS5N$$$JDCN-89HS6B$$$JDCN-89HS6Y$$$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-BECD9B$$$JDCN-89HTGE$$$JDCN-89HTH3$$$JDCN-89HTHQ$$$JDCN-89HTJD$$$JDCN-89HTK2$$$JDCN-89HTKP$$$JDCN-89HTLC$$$JDCN-89HTLZ$$$JDCN-89HTMN$$$JDCN-89HTNB$$$JDCN-89HTNY$$$JDCN-8UPFL5$$$JDCN-89HTW7$$$JDCN-89HTPM$$$JDCN-89HTQA$$$JDCN-89HTQX$$$JDCN-89HTRL$$$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$$$JDCN-B82GFQ$$$JDCN-89HU63$$$JDCN-89HU6Q$$$JDCN-89HU7D$$$JDCN-89HU82$$$JDCN-89HU8P$$$JDCN-89HU9C$$$JDCN-89HU9Z$$$JDCN-89HUAN$$$JDCN-89HUBB$$$JDCN-9LFTHP$$$JDCN-89HUBY Herzegovina$$$Cape Verde$$$Republic of Cameroon$$$People's Republic of China$$$Peoples Republic of China$$$Democratic Republic of the Congo$$$DRC$$$Republic of Congo$$$Channel Islands$$$Channel Islands$$$South Korea$$$Republic of Korea$$$Laos$$$Republic of Lebanon$$$The Netherlands$$$PNG$$$Russia$$$St. Lucia$$$St Lucia$$$Slovakia$$$SA$$$Tobago$$$Republic of Turkey$$$Turks$$$Caicos$$$UAE$$$Great Britain$$$UK$$$Britain$$$Whales$$$Northern Ireland$$$England$$$US$$$U.S.$$$U.S.A.$$$USA$$$Republic of Uruguay$$$Republic of Uzbekistan$$$Republic of Zambia

Tunisia Corporate - Withholding taxes

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The payments of certain remunerations are subject to corporate WHT in Tunisia.

The WHT is an advance payment of CIT and is thus deductible from the CIT due by the invoicing entity. To this end, the paying entity shall withhold the tax at the appropriate rate. It shall then issue a WHT certificate to the invoicing company to enable the latter to use the certificate as proof of the payment at the moment of filing its CIT return. The paying entity subsequently pays the withheld amount to the tax authorities.

The withheld tax is to be declared and repaid by the paying entity each month before the 28th day of the following month.

The rates of the WHT differ according to the nature of the goods/services and the rates applicable within the framework of the DTTs.

Applicable WHT rates in Tunisia are as follows:

  • 15% of the gross amount of the invoices related to fees, commissions, brokerage fees, rentals, payment of non-commercial activities.

    This rate is reduced to 5% for fees and hotel rentals when these amounts are paid to entities subject to CIT and individuals who keep proper accounts in accordance with the Tunisian accounting principles.

    This rate is reduced to 2.5% for fees, commissions, rentals, and non-commercial remunerations deriving from exportation, in accordance with the legislation in force. As per the Finance Law 2019, such reduced rate (2.5%) will no longer apply for companies active as at 31 December 2018 starting from 1 January 2021. For new entities created starting from 1 January 2019, the general rates will apply as of 1 January 2019.
     
  • 15% on performance bonus paid to distributors of goods.
  • 20% on interest and director’s attendance allowance. This does not include interest on deposits and bonds in foreign currency or convertible dinars.
  • 10% on bank loans granted by non-Tunisian resident banks.
  • 2.5% on the sales price indicated in a real estate sale, in case the seller is an individual.
  • 1.5% on payments exceeding TND 1,000 (including VAT) made for the acquisition of goods and services necessary to the activity and that are not subject to a specific WHT rate.

    This rate is reduced to 0.5% in case the remunerations are derived from exportation, in accordance with the legislation in force, or payment is made to companies subject to CIT at the rate of 10% and 13.5% (applicable as of 2021 for companies operating in listed industries) or revenues deductible from the PITable base up to 2/3 (applicable as of 2021 for individuals operating in listed industries) or 50% of their amount. As per the Finance Law 2019, such reduced rate (0.5%) will no longer apply regarding remunerations derived from exportation realised by companies active as at 31 December 2018 starting from 1 January 2021. For new entities created starting from 1 January 2019, the general rate will apply as of 1 January 2019.
     
  • 15% on other payments made to non-Tunisian tax resident persons (subject to more favourable rates provide by DTT).
  • 15% on other payments made to non-Tunisian tax resident persons deemed to have a PE in Tunisia and that fail to register with the tax authorities.
  • Dividends distributed by Tunisian-resident companies to non-resident, non-establishment companies, to non-resident individuals, and to resident individuals are subject to CIT paid through a discharging WHT at the rate of 10% of its total amount.
  • 25% on payments (payments for services, interests and director’s attendance allowances, dividends and branch tax, interests paid to banks) made to persons resident in tax havens. It should be noted that the Finance Law 2019 redefined the concept of 'tax havens' as 'countries or territories with a privileged tax regime', which are defined as countries or territories whose CIT rate is lower than 50% of the CIT rate due in Tunisia under the same activity. The list of the said countries/territories are fixed by a decision of the Finance Minister dated 25 March 2019. In addition, the Finance Law 2019 provided that the WHT due on payments related to services realised by companies tax resident or established in tax havens (listed by decision of the Finance Minister dated 25 March 2019) deemed to be realised under a PE located in Tunisia and that fail to register with the tax authorities are subject to the WHT at the rate of 25% instead of 15% applicable as per the domestic law.
  • 25% on lottery and gambling gain.

DTT rates

Note that the following interest WHT rates are applicable to interest payable to non-resident, non-PE companies and financial institutions according to DTTs concluded by Tunisia.

The DTT rate is applicable in case it is lower than the domestic law, provided that the beneficiary of the payment provides the corresponding tax residency certificate. In case of failure, the domestic law will be applied.

Recipient WHT (%)
Dividends (62, 67) Interest Royalties
Banks (45) Other companies
Non-treaty 10 10 20 15/25 (68)
Treaty:        
Austria 10/20 (63) 10 10 10/15 (1)
Belgium 5/15 (64) 5/10 (46) 10 11 (2)
Burkina Faso  8 0/5 (71) 0/5 (71) 5 (72)
Cameroon 12 15 15 15 (3)
Canada 15 15 15 15 (4)
China 8 0/10 (47) 10 5/10 (5)
Cote d'Ivoire  10 0/10 0/10 (75) 10 (76)
Czech Republic 10/15 (63) 12 12 5/15 (6)
Denmark 15 12 12 15 (7)
Egypt 10 10 10 15 (8)
Ethiopia 5 0/11 (48) 11 5 (9)
France 5 12 12 5/15 (10)
Germany 5/15 (64) 0/2,5 (49) 10 10 (11)
Greece 10 15 15 10 (12)
Hungary 10/12 (63) 12 12 12 (13)
Indonesia 12 12 12 15 (14)
Iran 10 0/10 (50) 10 8 (15)
Italy 15 0/12 (51) 12 5/12 (16)
Jordan 5 5 20 (17)
Kuwait 10 0/2.5 (52) 10 5 (18)
Lebanon 5 0/5 (53) 0/5 (54) 5 (19)
Luxemburg 10 7.5/10 (55) 10 12 (20)
Mali 0/5 (63) 5 5 (21)
Malta 10 12 12 12 (22)
Mauritius Islands 0 2.5 2.5 2.5 (23)
Netherlands 0/20 (64) 7.5/10 (56) 7.5/10 (56) 7.5/11 (24)
Norway 20 12 12 5/15 (25)
Pakistan 10 13 13 10 (26)
Poland 5/10 (63) 12 12 12 (27)
Portugal 15 15 15 10 (28)
Qatar 0 5 20 5 (29)
Romania 12 10 10 12 (22)
Saudi Arabia 5 2.5 5 5 (61)
Senegal 5 5 20 15 (30)
Serbia  10 10 10 10 (73)
South Africa 10 5 12 10/12 (31)
South Korea 15 0/12 (57) 12 15 (32)
Spain 5/15 (65) 5/10 (58) 5/10 (58) 10 (33)
Sudan 0/5 (63) 10 10 5 (34)
Sultanate of Oman 0 10 10 5 (35)
Sweden 15/20 (63) 12 12 5/15 (36)
Switzerland 10 10 10 10 (37)
Syria 0 10 10 15 (38)
Turkey 12/15 (63) 10 10 10 (39)
United Arab Emirates 0 5 (59) 10 7.5 (40)
United Kingdom 12/20 (63) 10 10/12 (74) 15 (41)
United Maghreb Arab 5 5 20 (42)
United States of America 14/20 (66) 0/15 (60) 15 10/15 (43)
Vietnam  10 10 10 (70) 10 (69)
Yemen 0 10 10 7.5 (44)

Notes

  1. 10% of the gross amount of the royalties for the use of, or the right to use, any copyright of literary, artistic, or scientific work. 15% of the gross amount of the royalties for cinematographic films and TV films, patents, trademarks, designs or models, plans, secret formulae, or processes; technical and economical studies; information concerning industrial, agricultural, commercial, or scientific experience; and the use of or the right to use industrial, commercial, or scientific equipment.
  2. 11% of the gross amount of the royalties for the use of, or the right to use, any copyright of literary, artistic or scientific work, including cinematographic films and films for TV broadcasting, patents, trademarks, designs or models, plans, secret formulae, or processes; information concerning industrial, commercial, or scientific experience; the use of, or the right to use, industrial, commercial, scientific equipment, or port facilities; and economical and technical studies, and technical assistance realised in the state of source.
  3. 15% of the gross amount of royalties for the use of, or the right to use, any copyright of literary, artistic, or scientific work, including cinematographic films, patents, trademarks, designs or models, plans, secret formulae, or processes; information concerning industrial, commercial, or scientific experience; the use of, or the right to use, industrial, commercial, or scientific equipment; and technical assistance and studies in all fields.
  4. 20% of the gross amount of the royalties for the use of, or the right to use, licences, trademarks, cinematographic films, and films and discs for radio or television broadcasting and the use of, or the right to use, industrial, commercial, scientific equipment, or port facilities; however, since the 20% treaty rate is higher than the 15% common law rate, the latter will be applied. 15% of the gross amount of the royalties for all the other cases, mainly technical and economical studies; the use of, or the right to use copyrights, patents, trademarks, designs or models, plans, secret formulae, or processes; and information concerning industrial, commercial, or scientific experience. However, royalties paid for the use of, or the right to use, copyrights of literary, dramatic, musical, or artistic work, except royalties in respect of cinematographic films and films and discs for TV broadcasting, are taxable in the state of residency and thus cannot be subject to tax nor to any WHT in connection with the state in which they arise.
  5. 10% of the gross amount of the royalties for the use of, or the right to use, any copyright of literary, artistic, or scientific work, including cinematographic films and films, tapes, or discs for radio or television broadcasting, patents, trademarks, designs or models, plans, secret formulae, or processes, and information in respect of industrial, commercial, or scientific experience. 5% of the gross amount of the royalties for technical and economical studies and technical assistance.
  6. 5% of the amount of the royalties for the use of, or the right to use, any copyright of literary, artistic, or scientific work, including cinematographic and films for TV and radio broadcasting. 15% of the amount of the royalties for the use of, or the right to use, patents, trademarks, designs or models, plans, secret formulae, or processes; information in respect of industrial, commercial, or scientific experience; the use of or the right to use industrial, commercial, or scientific equipment; and technical and economical studies and technical assistance rendered in the state in which they arise.
  7. 15% of the gross amount of royalties for the use of, or the right to use, any copyright of literary, artistic, or scientific work, including cinematographic films and films, tapes, or discs for radio or television broadcasting, patents, trademarks, designs or models, plans, secret formulae, or processes; information in respect of industrial, commercial, or scientific experience; the use of or the right to use industrial, commercial, or scientific equipment; and technical and economical studies.
  8. 15% of the gross amount of royalties for the right to publish any literary, artistic or scientific work, patents, trademarks, designs or models, plans, secret formulae or processes; information in respect of industrial, commercial or scientific experience; the use of or the right to use industrial, commercial or scientific equipment; and cartoons, films, and videos for TV broadcasting.
  9. 5% of the gross amount of royalties for the use of, or the right to use, any copyright of literary, artistic, or scientific work, including cinematographic films and films, tapes, or discs for radio or television broadcasting, patents, trademarks, designs or models, plans, secret formulae, or processes; information in respect of industrial, commercial, or scientific experience; and the use of, or the right to use, industrial, commercial, or scientific equipment.
  10. 5% of the gross amount of the royalties for the use of, or the right to use, any copyright of literary, artistic, or scientific work. 15% of the gross amount of the royalties for the use of, or the right to use, patents, trademarks, designs or models, plans, secret formulae, or processes; information in respect of industrial, commercial, or scientific experience; and economical and technical studies. 20% of the gross amount of the royalties for the use of, or the right to use, agricultural, industrial, commercial, scientific equipment, or port facilities and licences, trademarks, cinematographic films, and films for TV broadcasting. However, payments made to public entities for the use of cinematographic films or the broadcasting on radio and TV are exempt from WHT; however, since the 20% treaty rate is higher than the 15% common law rate, the latter will be applied.
  11. 10% of the gross amount of the royalties for the use of, or the right to use, any copyright of literary, artistic, or scientific work including cinematographic films or films for radio or  television; for patents, brand or trademarks, designs or models, plans, secret formulae, or processes, for the use or right to use of industrial, commercial or scientific equipment excluding ships or aircraft used in international traffic, for  information concerning industrial, commercial, or scientific experience; for technical and economical studies and for technical assistance..Also, the term "royalties" covers remuneration paid for the use or concession of the use of the name, image or other similar personality rights and those paid for the recording of show artists performances and sportspeople by radio and television channels.
  12. 10% of the gross amount of the royalties for the use of, or the right to use, any copyright of literary, artistic, or scientific work, including cinematographic films and films, tapes, or discs for radio or television broadcasting, patents, trademarks, designs or models, plans, secret formulae, or processes; information concerning industrial, commercial, or scientific experience; the use of, or the right to use, industrial, agricultural, commercial, scientific equipment, or port facilities, except remunerations for chartering of vessels and aircraft; and technical and economical studies.
  13. Royalties may be subject to tax in the contracting state in which they arise in cases where the legislation of that state allows such taxation, at a maximum rate of 12%.
  14. 15% of the gross amount of royalties for the use of, or the right to use, any copyright of literary, artistic, or scientific work, including cinematographic films and films, tapes, or discs for radio or television broadcasting, patents, trademarks, designs or models, plans, secret formulae, or processes; information in respect of industrial, commercial, or scientific experience; the use of, or the right to use, industrial, commercial, or scientific equipment; and technical services, such as technical and economical studies and technical assistance.
  15. 8% of the gross amount of royalties for the use of, or the right to use, any copyright of literary, artistic, or scientific work, including cinematographic films and films, tapes, or discs for radio or television broadcasting, patents, trademarks, designs or models, plans, secret formulae, or processes; information in respect of industrial, commercial, or scientific experience; and the use of, or the right to use, agricultural, industrial, commercial, scientific equipment, or port facilities, except remunerations for the chartering of vessels and aircraft used for international transport.
  16. 5% of the gross amount of the royalties for the use of, or the right to use, any copyright of literary, artistic, or scientific work. 12% of the gross amount of the royalties for the use of, or the right to use, patents, trademarks, designs or models, plans, secret formulae, or processes; information in respect of industrial, commercial, or scientific experience; and economical and technical studies. 16% of the gross amount of the royalties for the use of, or the right to use industrial, commercial, or scientific equipment, and licences, trademarks, cinematographic films, and films for TV broadcasting; however, since the 16% treaty rate is higher than the 15% common law rate, the latter will be applied.
  17. Royalties may be subject to tax in the contracting state in which they arise in case the legislation of that state allows such taxation and according to the legislation of that state for the use of, or the right to use, any copyright of literary, artistic, or scientific work, patents, trademarks, designs or models, plans, secret formulae, or processes; information in respect of industrial, commercial, or scientific experience; and the use of, or the right to use, industrial, commercial, or scientific equipment.
  18. 5% of the gross amount of royalties for the use of, or the right to use, any copyright of literary, artistic, or scientific work, including cinematographic films and films, tapes, or discs for radio or television broadcasting, patents, trademarks, designs or models, plans, secret formulae, or processes, and information in respect of industrial, commercial, or scientific experience.
  19. 5% of the gross amount of royalties for the use of, or the right to publish, any literary, artistic, or scientific work, including cinematographic films and films, tapes, or discs for radio or television broadcasting, a transmission by satellite or optical fibre transmission or similar means of transmission, patents, trademarks, designs or models, plans, secret formulae, or processes; information in respect of industrial, commercial, or scientific experience; and the use of, or the right to use, industrial, commercial, or scientific equipment.
  20. 12% of the gross amount of royalties for the use of, or the right to use, any copyright of literary, artistic, or scientific work, including cinematographic films, patents, trademarks, designs or models, plans, secret formulae, or processes; information in respect of industrial, commercial, or scientific experience, except remuneration for vessels and aircraft chartering in respect of international transport; the use of, or the right to use, industrial, agricultural, commercial, or scientific equipment; and technical services, such as technical and economical studies and technical assistance, carried out in the state of source.
  21. Royalties may be subject to tax in the contracting state in which they arise in cases where the legislation of that state allows such taxation and according to its legislation for the use of, or the right to use, any copyright of literary, artistic, or scientific work, including cinematographic films recording for radio or television broadcasting, patents, trademarks, designs or models, plans, secret formulae, or processes; information in respect of industrial, commercial, or scientific experience; and the use of, or the right to use, industrial, commercial, or scientific equipment.
  22. 12% of the gross amount of royalties for the use of, or the right to use, any copyright of literary, artistic, or scientific work, including cinematographic films and films, tapes, or discs for radio or television broadcasting, patents, trademarks, designs or models, plans, secret formulae, or processes; information in respect of industrial, commercial, or scientific experience; the use of, or the right to use, industrial, agricultural, commercial, or scientific equipment; and technical and economical studies and technical assistance.
  23. 2.5% of the gross amount of royalties for the use of, or the right to use, any copyright of literary, artistic, or scientific work, including cinematographic films, patents, trademarks, designs or models, plans, secret formulae, or processes; information in respect of industrial, commercial, or scientific experience; and the use of, or the right to use, industrial, agricultural, commercial, or scientific equipment, except remunerations for the chartering of vessels and aircraft used for international transport.
  24. Royalties may be subject to tax in the contracting state in which they arise in case the legislation of that state allows such taxation; but if the recipient is the beneficial owner of the royalties, the tax so charged shall not exceed 11% of their amount. However, this rate is reduced to 7.5% in case royalties received by a resident of Tunisia are not subject to WHT in the Netherlands and as long as the Netherlands does not proceed to the modification of its tax legislation. Remunerations paid for the following are considered royalties: the use of, or the right to use, any copyright of literary, artistic, or scientific work, including cinematographic films and films, tapes, or discs for radio or television broadcasting, patents, trademarks, designs or models, plans, secret formulae, or processes; information in respect of industrial, commercial, or scientific experience; the use of, or the right to use, industrial, commercial, or scientific equipment, except remunerations paid for the exploitation of vessels and aircraft in respect of international transport; and technical and economical studies and technical assistance rendered in the state from which royalties are paid.
  25. 5% of the gross amount of the royalties for the use of, or the right to use, any copyright of literary, artistic, or scientific work, except cinematographic films and films for TV broadcasting. 15% of the gross amount of the royalties for the use of, or the right to use, patents, trademarks, designs or models, plans, secret formulae, or processes; information in respect of industrial, commercial, or scientific experience; and economical and technical studies. 20% of the gross amount of the royalties for the use of, or the right to use, agricultural, industrial, commercial, scientific equipment, or port facilities, and the use of, or the right to use, trademarks and cinematographic films and films for TV broadcasting; however, since the 20% treaty rate is higher than the 15% common law rate, the latter will be applied.
  26. 10% of the gross amount of royalties for the use of, or the right to use, any copyright of literary, artistic, or scientific work, including cinematographic films, patents, trademarks, designs or models, plans, secret formulae, or processes; the use of, or the right to use, industrial, agricultural, commercial, scientific equipment, or port facilities, except remuneration for vessels and aircraft chartering in respect of international transport; and technical and economical studies and technical assistance.
  27. 12% of the gross amount of royalties for the use of, or the right to use, any copyright of literary, artistic, or scientific work, including cinematographic films, patents, trademarks, designs or models, plans, secret formulae, or processes; information in respect of industrial, commercial, or scientific experience; the use of, or the right to use, industrial, agricultural, commercial, scientific equipment, or port facilities; and technical and economical studies and technical assistance.
  28. 10% of the gross amount of royalties for the use of, or the right to use, any copyright of literary, artistic, or scientific work, including cinematographic films and films, tapes, or discs for radio or television broadcasting, patents, trademarks, designs or models, plans, secret formulae, or processes; information in respect of industrial, commercial, or scientific experience; the use of, or the right to use, industrial, commercial, or scientific equipment; and technical and economical studies and technical assistance in respect of the use of, or the right to use, the equipments, rights, and information mentioned above.
  29. 5% of the gross amount of royalties for the use of, or the right to use, any copyright of literary, artistic, or scientific work, patents, trademarks, designs or models, plans, secret formulae, or processes; information in respect of industrial, commercial, or scientific experience; and the use of or the right to use industrial, commercial, or scientific equipment.
  30. Royalties are subject to tax in the state of residency of the beneficiary. However, the non-exclusive taxation right attributable to the state of residency does not prohibit the taxation of such royalties in the state in which they arise in cases where the legislation of that state allows such taxation and according to its legislation. Remunerations paid for the following are considered royalties and thus are subject to tax in the state in which they arise: the use of, or the right to use, any copyright of literary, artistic, or scientific work, including cinematographic films, patents, trademarks, designs or models, plans, secret formulae, or processes; information in respect of industrial, commercial, or scientific experience; and the use of, or the right to use, industrial, commercial, or scientific equipment that is not considered as an asset in the meaning of Article 6 of the treaty.
  31. 10% of the gross amount of the royalties for the use of, or the right to use, any copyright of literary, artistic, or scientific work, including cinematographic films and films, tapes, or discs for radio or television broadcasting, patents, trademarks, designs or models, plans, secret formulae, or processes, and information in respect of industrial, commercial, or scientific experience. 12% of the gross amount of the royalties for technical services, such as technical and economical studies and technical assistance.
  32. 15% of the gross amount of royalties for the use of, or the right to use, any copyright of literary, artistic, or scientific work, including cinematographic films and films, tapes, or discs for radio or television broadcasting, patents, trademarks, designs or models, plans, secret formulae, or processes; the use of, or the right to use, industrial, agricultural, commercial, or scientific equipment; and economical and technical studies and technical assistance.
  33. 10% of the gross amount of royalties for copyrights, patents, trademarks, designs or models, plans, secret formulae, or processes; studies and information in respect of industrial, commercial, or scientific experience; the use of, or the right to use, industrial, commercial, or scientific equipment; and cinematographic films and video tapes for TV broadcasting.
  34. 5% of the gross amount of royalties for the use of, or the right to use, any copyright of literary, artistic, or scientific work, including cinematographic films and films, tapes, or discs for radio or television broadcasting, patents, trademarks, designs or models, plans, secret formulae, or processes; information in respect of industrial, commercial, or scientific experience; and the use of or the right to use industrial, agricultural, commercial, or scientific equipment, except chartering of ships and aircraft used for the international transport.
  35. 5% of the gross amount of royalties for remunerations paid for the use of, or the right to use, any copyright of literary, artistic, or scientific work, including cinematographic films and films, tapes, or discs for radio or television broadcasting, patents, trademarks, software, designs or models, plans, secret formulae, or processes.
  36. 5% of the amount of the royalties for the use of, or the right to use, any copyright of literary, artistic, or scientific work, excluding cinematographic and films for TV and radio broadcasting. 15% of the amount of the royalties for the use of, or the right to use, cinematographic films, films for TV and radio broadcasting, patents, trademarks, designs or models, plans, secret formulae, or processes; information in respect of industrial, commercial, or scientific experience; and the use of, or the right to use, industrial, commercial, or scientific equipment, and technical and economical studies.
  37. 10% of the gross amount of royalties for the use of, or the right to use, any copyright of literary, artistic, or scientific work, including cinematographic films, patents, trademarks, designs or models, plans, secret formulae, or processes; information in respect of industrial, commercial, or scientific experience, and technical and economical studies and technical assistance related to these information; and the use of, or the right to use, industrial, commercial, or scientific equipment.
  38. 18% of the gross amount of royalties for the use of, or the right to use patents, trademarks, designs or models, plans, secret formulae, or processes; information in respect of industrial, commercial, or scientific experience; and the use of, or the right to use, industrial, commercial, or scientific equipment; however, since the 18% treaty rate is higher than the 15% common law rate, the latter will be applied.
  39. 10% of the gross amount of royalties for the use of, or the right to use, any copyright of literary, artistic, or scientific work, including cinematographic films and films, tapes, or discs for radio or television broadcasting, patents, trademarks, designs or models, plans, secret formulae, or processes; information in respect of industrial, commercial, or scientific experience; and the use of, or the right to use, industrial, commercial, or scientific equipment.
  40. 7.5% of the gross amount of royalties for the use of, or the right to use, any copyright of literary, artistic, or scientific work, including cinematographic films and films, tapes, or discs for radio or television broadcasting, patents, trademarks, designs or models, plans, secret formulae, or processes; information in respect of industrial, commercial, or scientific experience; and the use, of or the right to use, industrial, commercial, or scientific equipment.
  41. 15% of the gross amount of royalties for the use of, or the right to use, any copyright of literary, artistic, or scientific work, including cinematographic films and films, tapes, or discs for radio or television broadcasting, patents, trademarks, designs or models, plans, secret formulae, or processes; information in respect of industrial, commercial, or scientific experience; the use of, or the right to use, industrial, agricultural, commercial, or scientific equipment; and technical and economical studies.
  42. Royalties are only taxable in the contracting state in which they arise in cases where the legislation of that state allows such taxation and according to its legislation for the use of, or the right to use, any copyright of literary, artistic, or scientific work, including cinematographic films and films for TV broadcasting, patents, trademarks, designs or models, plans, secret formulae, or processes; information in respect of industrial, commercial, or scientific experience; the use of, or the right to use, industrial, commercial, scientific equipment or port facilities; and economical and technical studies and economical assistance.
  43. 15% of the gross amount of the royalties for copyright of literary, artistic, or scientific work, including cinematographic films and films, tapes or discs for radio or television broadcasting, patents, trademarks, designs or models, plans, secret formulae, or processes; information in respect of industrial, commercial, or scientific experience; and profits from any ownership, depending from the productivity, the use, or the alienation of that ownership. 10% of the gross amount of the royalties for the use of, or the right to use, industrial, commercial, or scientific equipment other than vessels and aircraft used for international transport, and technical studies paid from public funds or political subdivisions or local authorities or technical assistance for the use of the ownership of the rights above mentioned, in case the technical assistance is realised in the state of source.
  44. 7.5% of the gross amount of royalties for the use of, or the right to use, any copyright of literary, artistic, or scientific work, including cinematographic films and films, tapes, or discs for radio or television broadcasting, patents, trademarks, designs or models, plans, secret formulae, or processes, and the use of, or the right to use, industrial, commercial, or scientific equipment and port facilities, except remunerations paid for vessels and aircraft used in international transport.
  45. These rates are applicable, in certain cases, to the loans extended by the Central Bank.
  46. 5% for loans extended by banks and not represented by bonds or other debt securities.
  47. 0% for loans granted by financial institutions, the capital of which is held up to 100% by the Chinese state.
  48. 0% for loans granted by financial institutions, the capital of which is held at least up to 50% by the Ethiopian state, its political subdivisions, or local authorities.
  49. 0% fo interests paid on loans granted with a guarantee from the Federal Republic of Germany for exports or direct foreign investments or paid to the Government of the Federal Republic of Germany. 0% for loans granted by the Deutsche Bundesbank, Kreditanstalt für Wiederaufbau, and the DEG - Deutsche Investitions- und Entwicklungsgesellschaft mbH.
  50. 0% for loans granted by financial institutions, the capital of which is held up to 100% by the state of Iran.
  51. 0% for loans granted by financial institutions, the capital of which is totally held by the Italian state or its local authorities.
  52. 0% for loans granted by financial institutions, the capital of which is held up to 100% by the state of Kuwait.
  53. 0% for loans granted by financial institutions, the capital of which is totally held by the state of Lebanon, its political subdivisions, or local authorities.
  54. 0% for loans granted by companies, the capital of which is totally held by the state of Lebanon, its political subdivisions, or local authorities.
  55. 7.5% for loans guaranteed or granted by financial institutions and the reimbursement period of which exceeds five years.
  56. 7.5% as long as the tax legislation of the Netherlands provides that interest paid by a company resident in the Netherlands to a company resident in Tunisia is exempt from any WHT.
  57. 0% for loans, the reimbursement period of which exceeds seven years.
  58. 5% for loans, the reimbursement period of which exceeds seven years, and 10% in the other cases.
  59. 5% for bank loans since the Tunisian domestic tax legislation provides that interest on bank loans extended by non-established banks is subject to a 5% WHT rate.
  60. 0% for loans granted by financial institutions, provided that the reimbursement period exceeds seven years.
  61. 5% of the gross amount of royalties for the use of, or the right to use, any copyright of literary, artistic, or scientific work, including cinematography and films for TV and radio broadcasting; the use of, or the right to use, patents, trademarks, designs or models, plans, secret formulae, or processes; information in respect of industrial, commercial, or scientific experience; and the use of, or the right to use industrial, commercial, or scientific equipment.
  62. According to the DTTs concluded by Tunisia, dividends are subject to the listed WHT tax rates, knowing that the rate provide by the domestic law is fixed at 5%.
  63. The lower rate applies in cases where the beneficiary has equity participation of 25%.
  64. The lower rate applies in cases where the beneficiary has equity participation of 10%.
  65. The lower rate applies in cases where the beneficiary has equity participation of 50%.
  66. The lower rate applies in cases where the beneficiary has equity participation of 25%, except for investment companies and real estate investment companies.
  67. Certain DTTs foresee that in case companies resident of a contracting state have a PE in the other contracting state (state of source), the latter may levy WHT on profits made by the PE as a taxation on dividend.
  68. 25% on payments made to persons resident in countries or territories with a privileged tax regime, which are defined as countries or territories whose CIT rate is lower than 50% of the CIT rate due in Tunisia under the same activity (listed by decision of the Finance Minister dated 25 March 2019).
  69. Royalties are subject to tax in the state of residency of the beneficiary. However, the non-exclusive taxation right attributable to the state of residency does not prohibit the taxation of such royalties in the state in which they arise in cases where the legislation of that state allows such taxation and according to its legislation. Remunerations paid for the following are considered royalties and thus are subject to tax in the state in which they arise: the use of, or the right to use, any copyright of literary, artistic, or scientific work, including cinematographic films or films and bands used for TV or radio programs, patents, trademarks, designs or models, plans, secret formulae or processes; and the use of, or the right to use of, industrial, commercial, port, agricultural, or scientific equipment; and information in respect of agricultural, industrial, commercial, or scientific experience. 
  70. Taxation in the country of source at the rate of 10%. Interests paid to the government of the other contracting state or its central bank and interests paid by the government of the state of source, its political subdivisions, its local communities, or its central bank are exempt. 
  71. Taxation in the country from source at the rate of 5%. Interests paid by the government, including a political subdivision or local community, or central bank to a bank belonging to the other state or a similar financial institution resident of the other contracting state are exempt. 
  72. Royalties are subject to tax in the state of residency of the beneficiary. However, the non-exclusive taxation right attributable to the state of residency does not prohibit the taxation of such royalties in the state in which they arise in cases where the legislation of that state allows such taxation and according to its legislation. Remunerations paid for the following are considered royalties and thus are subject to tax in the state in which they arise: the use of, or the right to use, any copyright of literary, artistic, or scientific work, including cinematographic films or films and bands used for radio or TV program, patents, trademarks, designs or models, plans, secret formulae or processes; and the use of industrial, commercial, port, agricultural, or scientific equipment.
  73. Royalties are subject to tax in the state of residency of the beneficiary. However, the non-exclusive taxation right attributable to the state of residency does not prohibit the taxation of such royalties in the state in which they arise in cases where the legislation of that state allows such taxation and according to its legislation. Remunerations paid for the following are considered royalties and thus are subject to tax in the state in which they arise: the use of, or the right to use, any copyright of literary, artistic, or scientific work, including cinematographic films, patents, trademarks, designs or models, plans, secret formulae or processes; and the use of, or the right to use of, industrial, commercial, or scientific equipment that is not considered as a immovable property in the meaning of Article 6 of the treaty; information in respect of industrial, commercial, or scientific experience. 
  74. The 10% rate will apply for interests paid to banks or financial institutions, and the 12% rate will apply to other interests. 
  75. Taxation in the country of source at the rate of 10%. Interests paid to the government of the other contracting state or its local communities or its central bank are exempt. 
  76. Royalties are subject to tax in the state of residency of the beneficiary. However, the non-exclusive taxation right attributable to the state of residency does not prohibit the taxation of such royalties in the state in which they arise in cases where the legislation of that state allows such taxation and according to its legislation. Remunerations paid for the following are considered royalties and thus are subject to tax in the state in which they arise: the use of, or the right to use, any copyright of literary, artistic, or scientific work, including cinematographic films, patents, trademarks, designs or models, plans, secret formulae or processes; and the use of, or the right to use of, industrial, commercial, or scientific equipment; information in respect of industrial, commercial, or scientific experience. 

Last Reviewed - 07 February 2020

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