Algeria

As explained in the Taxes on corporate income section, the WHT levied on services is 30%, which covers CIT, TPA, and VAT (i.e. three taxes in one). The calculation base is the gross amount of the services invoiced. In principle, it could be reduced or removed by a DTT.

The WHT levied on dividends (15% for both residents and non-residents) and the 10% WHT levied on interest can be reduced in the presence of a DTT.

In accordance with Article 46 of FL 2022, distributed profits between Algerian resident entities that have been previously subject to CIT undergo a 5% WHT.

The WHT levied on royalties is 30%. In the presence of a DTT, the WHT cannot exceed 5%, 10%, or 12%, depending on different cases.

Double tax treaty (DTT) rates

Notes

1. Equipment rental may be considered as royalties, or remuneration of services entering in the scope of industrial and commercial benefits, or other remuneration. Royalties paid for the use of industrial equipment in the frame of an international leasing contract is subject to a tax allowance of 60% applied based on such WHT. Thus, the effective tax rate of WHT will be 12% = 30% * (1 - 60%). For software, a reduction of 30% is applicable, making the effective tax rate 21%. VAT should be self-assessed in this case.
2. Domestic rate applies. There is no reduction under the treaty.
3. 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. 15% in all other cases.
4. 10% if the beneficial owner is resident in Algeria and interests sourced from France and 12% if the beneficial owner is resident in France and interests sourced from Algeria.
5. 5% for royalties paid for the use of, or the right to use, any copyright of literary, artistic, or scientific work, including cinematographic films, or films, tapes, and other means of image or sound reproduction. In other cases, 10% if royalties sourced from France and 12% if royalties sourced from Algeria.
6. DTT provisions entered into force on 1 January 2017 in Algeria for WHTs and other taxes.
7. 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. 15% in all other cases.
8. 0% if the interests are paid: (i) to the United Kingdom (UK) state, its central bank, a political subdivision, or a local authority, (ii) by the Algeria state, its central bank, a political subdivision, a local authority, or a statutory body, (iii) if the interests are paid in respect of a loan, debt-claim, or credit that is owed to, or made, provided, guaranteed, or insured by, Algeria, or a political subdivision, local authority, or export financing agency in Algeria. 7% in all other cases.
9. 10% of the gross amount of the dividends if the beneficial owner is a corporation that, for a consecutive period of two years, prior to the payment of the dividends, directly holds at least 25% of the share capital of the company paying the dividends. 15% of the gross amount of the dividends in all other cases.
10. 10% of the gross amount of the dividends if the beneficial owner is a (non-contracting) company that directly owns at least 25% of the capital of the company paying the dividends. 15% of the gross amount of the dividends in all other cases.
11. 5% of the gross amount of the dividends if the beneficial owner is a (non-contracting) company that directly owns at least 25% of the capital of the company paying the dividends. 15% of the gross amount of the dividends in all other cases.
12. 2% of the gross amount of royalties that are paid for the use of, or right to use, any industrial, commercial, or scientific equipment. 10% of the gross amount of the royalties in all other cases.
13. 5% of the gross amount of the dividends if the beneficial owner is a company that directly or indirectly holds at least 10% of the capital of the company paying the dividends. 15% of the gross amount of the dividends in all other cases.
14. 14% of the gross amount of the royalties paid for the use of, or the right to use, a copy of a literary, artistic, or scientific work, including motion pictures or films, tapes, and any other means of image or sound reproduction. 7% of the gross amount of royalties in other cases.
15. 5% of the gross amount of the dividends if the beneficial owner is a corporation (other than a partnership) that directly owns 20% of the capital of the company paying the dividends. 15% of the gross amount of the dividends in all other cases.
16. 5% of the gross amount of the dividends if the beneficial owner is a company (other than a company of persons) that directly owns at least 10% of the capital of the company paying the dividends. 15% of the gross amount of the dividends in all other cases.
17. 5% of the gross amount of the dividends if the beneficial owner is a corporation (other than a partnership) that directly holds at least 10% of the capital of the corporation that pays the dividends. 15% of the gross amount of the dividends in all other cases.
18. 5% of the gross amount of the dividends if the beneficial owner is a (non-contracting) company that directly owns at least 15% of the capital of the company paying the dividends. 10% of the gross amount of the dividends in all other cases.
19. 5% of the gross amount of the dividends if the beneficial owner is a (non-contracting) company that directly owns at least 25% of the capital of the company paying the dividends. 10% of the gross amount of the dividends in all other cases.