Tax Treaty Brief: December 2023


Belarus and Equatorial GuineaOn 28 November 2023, Mr. Alexander Lukashenko, the President of Belarus signed a decree that grants approval to negotiate and sign of a Double Taxation Agreement (DTA) with Equatorial Guinea.Moldova and NetherlandsOn 24 November 2023, the Moldovan parliament approved the amending protocol to the Double Taxation Agreement (DTA) with the Netherlands.Slovenia and SwitzerlandOn 22 November 2023, the Swiss Federal Council adopted the dispatch on the protocol of amendment to the Double Taxation Agreement (DTA) with Slovenia. The protocol implements the OECD’s minimum standards from the base erosion and profit shifting (BEPS) project with regard to double taxation agreements.Estonia and PakistanOn 20 November 2023, the Govt. officials from Estonia and Pakistan signed a Double Taxation Agreement (DTA) between two nations.Saudi Arabia and Slovak RepublicOn 13 November 2023, the Govt. officials from Saudi Arabia and the Slovak Republic signed a Double Taxation Agreement (DTA) between two nations.Korea, Rep Of and RwandaOn 13 November 2023, Rwanda’s lower house of parliament granted approval for the ratification of the Double Taxation Agreement (DTA) with South Korea.Kazakhstan and OmanOn 10 November 2023, Prime Minister Mr. Alikhan Smailov of Kazakhstan authorized the Minister of Finance to sign a Double Taxation Agreement (DTA) with Oman.Gambia and Saudi ArabiaOn 9 November 2023, the Govt. officials from Gambia and Saudi Arabia signed a Double Taxation Agreement (DTA) between two nations for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.Austria, China, Germany, and New ZealandOn 8 November 2023, the Austrian Federal Council approved the amending protocols to the
Double Taxation Agreements (DTAs) with China, Germany, and New Zealand.Australia and IcelandOn 6 November 2023, the Double Taxation Agreement (DTA) between Australia and Iceland entered into force. The DTA contains withholding tax rates for Dividends 5% for at least 10% capital holding; otherwise, 15%, Interest 10%, and Royalties 5%. The DTA generally applies from 1 January 2024.Kyrgyzstan and NetherlandsOn 3 November 2023, the Netherlands Council of Ministers granted authorization to the Minister of Foreign Affairs to officially sign a Double Taxation Agreement (DTA) with Kyrgyzstan.Jersey and MauritiusOn 3 November 2023, the Cabinet of Mauritius granted approval for the signing of an amending protocol to update the Double Taxation Agreement (DTA) with Jersey.Andorra and Korea, Rep OfOn 3 November 2023, the Govt. officials from Andorra and South Korea signed a Double Taxation Agreement (DTA) between two nations for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.San Marino and United KingdomOn 3 November 2023, San Marino ratified the Double Taxation Agreement (DTA) with the United Kingdom.Switzerland and TajikistanOn 2 November 2023, the amending protocol to the Double Taxation Agreement (DTA) between Switzerland and Tajikistan entered into force. The protocol implements the BEPS minimum standards for double taxation agreements.Malaysia and RussiaOn 2 November 2023, the Russian government authorized the Ministry of Finance to sign a new Double Taxation Agreement (DTA) with Malaysia. Once in force and effective, the new DTA will replace the former DTA of 1987.Cambodia and SingaporeOn 2 November 2023, Cambodia and Singapore signed an amending protocol to update the Double Taxation Agreement (DTA) between two nations.Andorra and MonacoOn 1 November 2023, Andorra officially announced that the Double Taxation Agreement (DTA) with Monaco became effective as of 22 July 2023. The DTA contains withholding tax rates for Dividends 0%, Interest 0%, and Royalties 5%. The DTA applies from 1 January 2024.Greece and JapanOn 1 November 2023, the Govt. officials from Greece and Japan signed a Double Taxation Agreement (DTA) between two nations. The DTA contains withholding tax rates for Dividends 5% for at least 10% capital holding; otherwise, 10%, Interest 10%, and Royalties 5%.Andorra and CroatiaOn 31 October 2023, the Double Taxation Agreement (DTA) between Andorra and Croatia entered into force. The DTA generally applies from 1 January 2024.Qatar and Saudi ArabiaOn 31 October 2023, the Council of Ministers in Saudi Arabia granted approval for the signing of a Double Taxation Agreement (DTA) with Qatar.France and MoldovaOn 31 October 2023, the French Council of Ministers granted approval to the Double Taxation Agreement (DTA) with Moldova. Subsequently, the DTA has been forwarded to the Senate for further approval.Andorra and Czech RepublicOn 31 October 2023, the Double Taxation Agreement (DTA) between Andorra and Czech Republic entered into force. The DTA generally applies from 1 January 2024. The DTA contains withholding tax rates for Dividends 5% for at least 10% capital holding; otherwise, 10%, Interest 0%, and Royalties 5% for any copyright of literary, artistic, or scientific work including cinematograph films; otherwise, 10%.Serbia and SwitzerlandOn 27 October 2023, Mr. Aleksandar Vučić, the President of Serbia signed a law ratifying the amending protocol to the Double Taxation Agreement (DTA) with Switzerland.Curacao and San MarinoOn 27 October 2023, the Council of Ministers in the Netherlands granted authorization to the Minister of Foreign Affairs to officially sign a Double Taxation Agreement (DTA) with San Marino on behalf of Curacao.Ukraine and United Arab EmiratesOn 19 October 2023, the amending protocol to the Double Taxation Agreement (DTA) between Ukraine and the United Arab Emirates (UAE) entered into force. The protocol will apply from 1 January 2024.Qatar and UkraineOn 11 June 2023, the amending protocol to the Double Taxation Agreement (DTA) between Qatar and Ukraine entered into force. The protocol generally applies from 1 January 2024.



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