Tax Treaty Brief: November 2023


Croatia and CyprusOn 27 October 2023, Cyprus ratified the Double Taxation Agreement (DTA) with Croatia.Cambodia, Congo (Dem. Rep.), Senegal, Sri Lanka, and TurkeyOn 26 October 2023, the Turkish Parliament approved the Double Taxation Agreements (DTAs) with Cambodia, Congo (Dem. Rep.), Senegal, and Sri Lanka for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.Serbia and SwitzerlandOn 26 October 2023, the Serbian parliament approved the amending protocol to the Double Taxation Agreement (DTA) with Switzerland.Denmark, France, and GreeceOn 26 October 2023, the French Senate approved the Double Taxation Agreements (DTAs) with Denmark and Greece.Germany and SwedenOn 25 October 2023, the Swedish parliament approved the amending protocol to the Double Taxation Agreement (DTA) with Germany.San Marino and United KingdomOn 24 October 2023, San Marino’s parliament approved the Double Taxation Agreement (DTA) with the United Kingdom.Korea, Rep Of and RwandaOn 20 October 2023, the Rwandan Cabinet granted approval to the draft law for the ratification of the Double Taxation Agreement (DTA) with South Korea.Germany and SwedenOn 20 October 2023, Germany ratified the amending protocol to the Double Taxation Agreement (DTA) with Sweden.Egypt and QatarOn 19 October 2023, Egypt officially released Decision No. 254 of 2023 through the Official Gazette, which provides for the ratification of the Double Taxation Agreement (DTA) with Qatar. The DTA contains withholding tax rates for Dividends 5% for at least 10% capital holding; otherwise, 10%, Interest 10%, and Royalties 10%.Austria, Germany, and LuxembourgOn 19 October 2023, the German lower house of parliament approved the amending protocols to the Double Taxation Agreements (DTAs) with Austria and Luxembourg.Luxembourg and RomaniaOn 18 October 2023, the Romanian Senate approved the amending protocol to the Double Taxation Agreement (DTA) with Luxembourg.Czech Republic and RwandaOn 18 October 2023, the Czech Senate approved the Double Taxation Agreement (DTA) with Rwanda.Austria, China, and New ZealandOn 18 October 2023, the Austrian National Council approved the amending protocols to the Double Taxation Agreements (DTAs) with China and New Zealand.Oman and RussiaOn 18 October 2023, Russia approved the law for the ratification of the Double Taxation Agreement (DTA) with Oman.Austria and GermanyOn 18 October 2023, the Austrian National Council approved the amending protocol to the Double Taxation Agreement (DTA) with Germany.Cameroon, China, and SenegalOn 17 October 2023, China signed Double Taxation Agreements (DTAs) with Cameroon and Senegal for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.Croatia and CyprusOn 17 October 2023, the Govt. officials from Croatia and Cyprus signed a Double Taxation Agreement (DTA) between two nations. Once in force and effective, the new DTA will replace the former DTA of 1985.Andorra and NetherlandsOn 12 October 2023, the Double Taxation Agreement (DTA) between Andorra and the Netherlands was signed for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.United Arab Emirates and TanzaniaOn 9 October 2023, the United Arab Emirates (UAE) Cabinet approved the Double Taxation Agreement (DTA) with Tanzania.Andorra and Czech RepublicOn 6 October 2023, Mr. Petr Pavel, the Czech President approved the ratification of the Double Taxation Agreement (DTA) with Andorra.Albania and Slovak RepublicOn 5 October 2023, Albania officially released Law No.73/2023 through the Official Gazette, which provides for the ratification of the Double Taxation Agreement (DTA) with Slovak Republic.Nigeria, Sierra Leone, and TurkeyOn 5 October 2023, the Turkish Parliament approved the Double Taxation Agreements (DTAs) with Sierra Leone and Nigeria.Luxembourg and United KingdomOn 4 October 2023, Luxembourg officially released Law of 18 September 2023 through the Official Gazette, which provides for the ratification of the Double Taxation Agreement (DTA) with the United Kingdom. Once in force and effective, the new DTA will replace the former DTA of 1967.France, Japan, and LithuaniaOn 4 October 2023, the French tax authorities implemented the most favored nation (MFN) clauses on interest and royalties as outlined in paragraphs 8 and 9 of the protocol to the Double Taxation Agreement (DTA) with Lithuania. This decision was triggered by the entry into force of the DTA between Japan and Lithuania.Azerbaijan and Slovak RepublicOn 2 October 2023, the Azerbaijani parliament approved the Double Taxation Agreement (DTA) with the Slovak Republic.Czech Republic and RussiaOn 29 September 2023, the Czech Republic officially released Financial Bulletin No. 10/2023, confirming the suspension of the Double Taxation Agreement (DTA) with Russia. This action is consistent with Russia’s decision to suspend 38 DTAs, including the DTA between Czech Republic and Russia.Slovenia and SwitzerlandOn 28 September 2023, Slovenia ratified the amending protocol to the Double Taxation Agreement (DTA) with Switzerland.Qatar and UkraineOn 16 August 2023, Mr. Tamim bin Hamad, the Qatari Emir issued instrument of ratification of the amending protocol to the Double Taxation Agreement (DTA) with Ukraine.



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