Traités de non double imposition du Royaume-Uni

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création de société anglaise au royaume-uni, UK

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Traités de non double imposition du Royaume-Uni

Une convention de double imposition permet que l’impôt payé peut être compensée dans l’un des deux pays par l’impôt dû dans l’autre, évitant ainsi la double imposition. Le Royaume-Uni est signataire de conventions de double imposition avec plusieurs pays à travers le monde. Certaines formes de revenus sont exonérés d’impôt ou de taxes réduites. Ceux-ci comprennent les redevances, dividendes et gains en capital.

Jurisdiction	Status	Dividends	Interest	Royalties	Notes

Defaults		0% (1)	20% (2)	20% (2)

Albania	Effective April 1, 2014	0%	0% when paid by the government, or to the government, the central bank, a financial institution or a pension fund, or on a loan or credit financed, guaranteed or insured by the government, or on sales on credit of equipment, merchandise or services 6%	0%
Antigua and Barbuda	Effective January 1, 1947	0%	20% (3)	0%
Argentina	Effective April 1, 1998	0%	0% when paid by the government, or on a loan or credit financed, guaranteed or insured by the government, or on a bank loan financed for at least five years, or on sales on credit of equipment 12%	3% for news royalties 5% for literary, artistic, dramatic or musical copyright royalties (excluding broadcasting royalties) 10% for the use of any patent, trademark, design or model, plan, secret formula or process, or industrial or scientific experience information or equipment 15%
Armenia	Effective January 1, 2013	0%	0% when paid to the government or the central bank 5%	5%
Australia	Effective July 1, 2004	0%	0% when paid to the government, the central bank or an independent financial institution (excluding bank-to-back loans) 10%	5%
Austria	Effective April 1, 1969	0%	0%	0% 10% where the payee is a company holding more than 50% of the paying company’s voting stock
Azerbaijan	Effective April 1, 1996	0%	0% when paid to the government, or on a loan or credit financed, guaranteed or insured by the central bank 10%	5% for literary or artistic copyrights or broadcasting royalties 10%
Bahrain	Effective January 1, 2013	0%	0% when paid by the government or a bank, or to the government, a pension fund, a company either traded on a recognised stock exchange or less than 25% owned by non-residents, or an independent financial institution (excluding bank-to-back loans) 20% (3)	0%
Bangladesh	Effective April 1, 1978	0%	0% when paid to the government 7.5% when paid to a bank, financial institution or insurance company 10%	10%
Barbados	Effective April 1, 2013	0%	0%	0%
Belarus	Effective April 1, 1986 New treaty signed March 7, 1995	0%	0% When new treaty is effective: 0% when paid to or by the government, or on a loan financed, guaranteed or insured by a financial institution to promote exports or development, or on sales on credit of equipment 5%	0% When new treaty is effective: 3% for the use of any patent, secret formula or process, or information concerning industrial, commercial or scientific experience 5%	The USSR treaty continues to apply. New treaty not yet in force.
Belgium	Effective April 1, 1990 Protocol effective April 1, 2013	0%	0% when paid to the government or a pension fund, or on a loan or credit financed between companies 10%	0%
Belize	Effective January 1, 1947	0%	20% (3)	0%
Bolivia	Effective April 1, 1996	0%	0% when paid to the government 15%	15%
Bosnia and Herzegovina	Effective April 1, 1983	0%	10%	10%	The Yugoslavia treaty continues to apply.
Botswana	Effective April 1, 2007	0%	0% when paid to the government, or on a loan financed, guaranteed or insured by a specified institution 10%	10%
Brunei	Effective April 1, 1950	0%	20% (3)	0%
Bulgaria	Effective April 1, 1998	0%	0%	0%
Canada	Effective April 1, 1976 Protocol effective April 1, 2005	0%	0% when paid on a loan or credit financed, guaranteed or insured by a specified institution, or on sales on credit of equipment, merchandise or services 10%	0% for the use of any literary, artistic, dramatic or musical copyright (excluding broadcasting royalties), computer software or patent, or information concerning industrial, commercial or scientific experience (excluding a rental or franchise agreement) 10%
Cayman Islands	Effective April 1, 2011	0%	0%	0%
Chile	Effective April 1, 2005	0%	5% when paid on a bank or insurance company loan, or on bonds or securities regularly traded on a recognised securities market, or on sales on credit of equipment or machinery 15%	5% for equipment royalties 10%
China	Effective April 1, 2014	0%	0% when paid to the government or the central bank, or on a loan or credit financed, guaranteed or insured by the government or the central bank 10%	6% for equipment royalties 10%
Cote d’Ivoire	Effective April 1, 1988	0%	0% when paid to the government 15%	10%
Croatia	Effective April 1, 1983	0%	10%	10%	The Yugoslavia treaty continues to apply.
Cyprus	Effective April 1, 1973	0%	10%	0% 5% for broadcasting royalties
Czech Republic	Effective April 1, 1992	0%	0%	0% for copyright or broadcasting royalties 10%	The Czechoslovakia treaty continues to apply.
Denmark	Effective April 1, 1978	0%	0%	0%
Egypt	Effective April 1, 1997	0%	0% when paid to the government 15%	15%
Estonia	Effective April 1, 1995	0%	0% when paid to or by the government, or on a loan or credit financed, guaranteed or insured by a government approved institution, or on a loan financed, guaranteed or insured by the central bank 10%	5% for equipment royalties 10%
Ethiopia	Effective April 1, 2013	0%	0% when paid to or by the government or the central bank 5%	7.50%
Falkland Islands	Effective April 1, 1997	0%	0%	0%
Faroe Islands	Effective April 1, 2009	0%	0%	0%
Fiji	Effective April 1, 1975	0%	10%	0% for copyright royalties (excluding broadcasting royalties) 15%
Finland	Effective April 1, 1968	0%	0%	0%
France	Effective April 1, 2010	0%	0%	0%
Gambia	Effective April 1, 1980	0%	0% when paid to the government or the central bank 15%	12.50%
Georgia	Effective April 1, 2006	0%	0%	0%
Germany	Effective January 1, 2011	0%	0%	0%
Ghana	Effective April 1, 1995	0%	0% when paid to the government 12.5%	12.5% 20% for broadcasting royalties (3)
Greece	Effective April 1, 1952	0%	0%	0%
Grenada	Effective April 1, 1949	0%	20% (3)	0%
Guyana	Effective April 1, 1993	0%	0% when paid to the government 15%	10% 20% for broadcasting royalties (3)
Hong Kong	Effective April 1, 2011	0%	0% when paid by the government or a bank, or to the government, the central bank, a pension fund, a company traded on a recognised stock exchange, or an independent financial institution (excluding bank-to-back loans) 20% (3)	3%
Hungary	Effective January 1, 2012	0%	0%	0%
Iceland	Effective April 1, 1992 New treaty signed December 17, 2013	0%	0%	0% When new treaty is effective: 5%	New treaty not yet in force.
India	Effective April 1, 1994	0%	0% when paid to the government or the central bank, or on a loan or credit financed, guaranteed or insured by a specified institution 10% when paid to a bank 15%	10% for equipment royalties 15%
Indonesia	Effective April 1, 1995	0%	0% when paid to the government or the central bank, or on a loan or credit financed, guaranteed or insured by the government or the central bank 10%	10% for equipment royalties 15%
Ireland	Effective April 1, 1976	0%	0%	0%
Israel	Effective January 1, 1961	0%	15%	0% 15% for broadcasting royalties
Italy	Effective April 1, 1991	0%	0% when paid by the government, or on a loan financed, guaranteed or insured by the government, or on sales on credit of equipment or goods 10%	8%
Jamaica	Effective April 1, 1973	0%	0% when paid to the government 12.5%	10%
Japan	Effective January 1, 2007	0%	0% when paid to the government, the central bank, a bank, an insurance company, a securities dealer or a pension fund, or on a loan or credit guaranteed, insured or indirectly financed by the government or the central bank, or on sales on credit of equipment or merchandise 10%	0%
Jordan	Effective April 1, 2003	0%	0% when paid to the government or the central bank 10%	10%
Kazakhstan	Effective April 1, 1993 Protocol effective April 1, 1999	0%	0% when paid to or by the government 10%	10%
Kenya	Effective April 1, 1973	0%	0% when paid to the government or the central bank 15%	15%
Kiribati	Effective April 1, 1949	0%	20% (3)	0%
Korea, South	Effective April 1, 1997	0%	0% when paid to the government or the central bank 10%	2% for equipment royalties 10%
Kuwait	Effective April 1, 2001	0%	0%	10%
Latvia	Effective April 1, 1997	0%	0% when paid to or by the government, or on a loan or credit financed, guaranteed or insured by a specified institution, or on a loan financed, guaranteed or insured by the central bank 10%	5% for equipment royalties 10%
Lesotho	Effective April 1, 1998	0%	0% when paid to the government 10%	10%
Libya	Effective April 1, 2010	0%	0%	0%
Liechtenstein	Effective February 1, 2013	0%	0%	0%
Lithuania	Effective April 1, 2002	0%	0% when paid to or by the government, or on a loan or credit financed, guaranteed or insured by a government approved institution, or on a loan financed, guaranteed or insured by the central bank, or on sales on credit of equipment 10%	5% for equipment royalties 10%
Luxembourg	Effective April 1, 1966	0%	0%	5%
Macedonia	Effective April 1, 2008	0%	0% when paid to the government, or on a loan or credit financed by a company to a company 10%	0%
Malawi	Effective April 1, 1953	0%	0%	0%
Malaysia	Effective April 1, 1999	0%	0% when paid to the government or the central bank, or on a loan or credit financed, guaranteed or insured by the government or the central bank 10%	8%
Malta	Effective April 1, 1996	0%	0% when paid to the government, or on a loan or credit financed, guaranteed or insured by the government 10%	10%
Mauritius	Effective April 1, 1981	0%	0% when paid to the government or a bank 20% (3)	15%
Mexico	Effective April 1, 1994	0%	0% when paid to or by the government or the central bank, or to a pension fund, or on a loan or credit financed, guaranteed or insured for at least three years by a specified institution 5% when paid to a bank or insurance company, or on bonds or securities regularly traded on a recognised securities market 10% when paid by a bank, or on sales on credit of equipment or machinery 15%	10%
Moldova	Effective April 1, 2009	0%	0% when paid by the government, or to the government, the central bank or a financial institution, or on a loan or credit financed, guaranteed or insured by the government, or on sales on credit of equipment 5%	5%
Mongolia	Effective April 1, 1997	0%	0% when paid to the government, or on a loan or credit financed, guaranteed or insured by a specified institution 7% when paid to a bank 10%	5%
Montserrat	Effective January 1, 1947	0%	20% (3)	0%
Morocco	Effective April 1, 1981	0%	0% when paid to the government 10%	10%
Namibia	Effective January 1, 1962	0%	20% (3)	0% for literary, artistic, dramatic or musical copyright royalties (excluding broadcasting royalties) 5%
Netherlands	Effective April 1, 2011	0%	0%	0%
New Zealand	Effective April 1, 1985	0%	0% when paid to the government, or on a loan or credit financed, guaranteed or insured by a specified institution 10%	10%
Nigeria	Effective April 1 1988	0%	0% when paid to the government 12.5%	12.50%
Norway	Effective April 1, 2014	0%	0%	0%
Oman	Effective April 1, 1996 Protocol effective January 1, 2012	0%	0%	8%
Pakistan	Effective April 1, 1998	0%	0% when paid to the government 15%	12.50%
Panama	Effective January 1, 2014	0%	0% when paid to the government, the central bank or a pension fund, or on financing approved by both governments, or on sales on credit of equipment or merchandise 5%	5%
Papua New Guinea	Effective April 1, 1992	0%	0% when paid to the government 10%	10%
Philippines	Effective April 1, 1997	0%	0% when paid to the government, or on a loan financed, guaranteed or insured by a government approved institution 10% when paid on public issues of bonds or debentures 15%	15% for broadcasting royalties 20% (4)
Poland	Effective January 1, 2007	0%	0% when paid to the government or the central bank, or on a loan financed, guaranteed or insured by a government institution to promote exports, or on a bank loan, or on sales on credit of equipment 5%	5%
Portugal	Effective April 1, 1970	0%	10%	5%
Qatar	Effective January 1, 2011	0%	0% when paid by the government or a bank, or to the government, a pension fund, a company either traded on a recognised stock exchange or less than 25% owned by non-residents, or an independent financial institution (excluding bank-to-back loans) 20% (3)	5%
Romania	Effective April 1, 1976	0%	10%	10% for copyright or broadcasting royalties 15%
Russia	Effective April 1, 1998	0%	0%	0%
Saint Kitts	Effective April 1, 1947	0%	20% (3)	0%
Saudi Arabia	Effective April 1, 2010	0%	0%	5% for equipment royalties 8%
Montenegro	Effective April 1, 1983	0%	10%	10%	The Yugoslavia treaty continues to apply.
Sierra Leone	Effective April 1, 1946	0%	20% (3)	0%
Singapore	Effective April 1, 1998 Protocol effective April 1, 2013	0%	0% when paid to the government or the central bank, or between banks or financial institutions 5%	8%
Slovakia	Effective April 1, 1992	0%	0%	0% for copyright or broadcasting royalties 10%	The Czechoslovakia treaty continues to apply.
Slovenia	Effective January 1, 2009	0%	0% when paid to or by the government, or on a loan or credit financed, guaranteed or insured by a specified institution, or on a loan financed, guaranteed or insured by the central bank 5%	5%
Solomon Islands	Effective April 6, 1949	0%	20% (2)	0%
South Africa	Effective April 1, 2003	0%	0%	0%
Spain	Effective April 1, 1976 New treaty signed March 14, 2013	0%	12% When new treaty is effective: 0%	10% When new treaty is effective: 0%	New treaty not yet in force.
Sri Lanka	Effective April 1, 1977	0%	0% when paid to a bank or financial institution 10%	0% for copyright or broadcasting royalties 10%
Sudan	Effective April 1, 1975	0%	15%	10%
Swaziland	Effective April 1, 1968	0%	20% (3)	0%
Sweden	Effective April 1, 1984	0%	0%	0%
Switzerland	Effective April 1, 1978	0%	0%	0%
Taiwan	Effective April 1, 2003	0%	0% when paid to the government, or on a loan or credit financed, guaranteed or insured by a government approved institution 10%	10%
Tajikistan	Effective April 1, 1986	0%	0%	0%	The USSR treaty continues to apply.
Thailand	Effective April 1, 1981	0%	0% when paid to the government or the central bank 10% when paid to a bank, financial institution or insurance company 20% (4)	5% for copyright royalties (excluding broadcasting royalties) 15%
Trinidad and Tobago	Effective April 1, 1984	0%	0% when paid to the government 10%	0% for copyright royalties (excluding broadcasting royalties) 10%
Tunisia	Effective April 1, 1985	0%	10% when paid to a bank or financial institution 12%	15%
Turkey	Effective April 1, 1989	0%	0% when paid to the government or the central bank 15%	10%
Turkmenistan	Effective April 1, 1986	0%	0%	0%	The USSR treaty continues to apply.
Tuvalu	Effective April 1, 1949	0%	20% (3)	0%
Uganda	Effective April 1, 1994	0%	0% when paid to the government, or on a loan or credit guaranteed or insured by the government 15%	15%
Ukraine	Effective April 1, 1994	0%	0%	0%
United States	Effective May 1, 2003	0%	0%	0%
Uzbekistan	Effective April 1, 1995	0%	0% when paid to the government, or on a loan or credit financed, guaranteed or insured by a specified institution 5%	5%
Venezuela	Effective April 1, 1997	0%	0% when paid to or by the government, or on a loan or credit financed, guaranteed or insured by a specified institution 5%	5% 7% for copyright or broadcasting royalties
Vietnam	Effective April 1, 1995	0%	0% when paid to the government 10%	10%
Zambia	Effective April 1, 1972 New treaty signed February 4, 2014	0%	10% When new treaty is effective: 0% when paid to the government or the central bank 10%	10% When new treaty is effective: 5%	New treaty not yet in force.
Zimbabwe	Effective April 1, 1981	0%	0% when paid to the government 10%	10%
Serbia	Effective April 1, 1983	0%	10%	10%	The Yugoslavia treaty continues to apply.
Myanmar	Effective April 1, 1948	0%	20% (3)	0%

Notes

1. The United Kingdom’s default dividends withholding tax rate is 0%. A treaty may stipulate a higher rate.

2. In the case of European Union countries, the EC Interest and Royalties Directive can reduce interest and royalties withholding tax to 0%, subject to certain conditions.

3. The domestic rate applies.

4. The treaty specifies a different rate but the default rate is lower and would therefore apply.

Traités de non double imposition du Royaume-Uni

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Traités de non double imposition du Royaume-Uni