Withholding Tax Rates Table

Withholding tax rates for dividends, interests and royalties according to the

double tax conventions in force

(Last update: March 2014)

Withholding tax rates for dividends, interests and royalties according to the double tax conventions in force (%)

This document has merely informative purposes. Its publication does not grant

rights nor benefits other than those provided by the double tax conventions in force.

Servicio de Administracin Tributaria Av. Hidalgo, nm. 77, Col. Guerrero, Delegacin Cuauhtmoc, Mxico, D. F., C.P. 06300 Tel. +52 (55) 5802 2313 document available in www.sat.gob.mx

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MFN: Most favoured nation.

1 See article 10, paragraph 2, subparagraph (a) of the relevant Convention.

2 See article 11, paragraph 2, subparagraph (a), sections (i) and (iii) of the relevant Convention.

3 See article 11, paragraph 2, subparagraph (a), sections (ii) and (iv) of the relevant Convention.

4 See article 10, subparagraph 2, section a).

Dividends Interests Royalties Country Substantial

shareholding MFN General MFN Financial

Sector MFN General MFN General MFN

1. Australia 0(1) --- 15 --- 10(2) --- 10(3)/15 --- 10 --- 2. Austria 5(4) --- 10 --- 10 --- 10 --- 10 --- 3. Bahrain ---(5) --- ---(5) --- 4.9(6) --- 10 --- 10 --- 4. Barbados 5(7) --- 10 --- 10 --- 10 --- 10 --- 5. Belgium 5(7) --- 15 --- 10(8) --- 15 --- 10 --- 6. Brazil 10(7) --- 15 --- 15 --- 15 --- 15 10(9)/15(10) 7. Canada 5(7) --- 15 --- 10 --- 10 --- 10 --- 8. Chile 5(7) --- 10 --- 15 5(11) 15 10(12) 15 10(13) 9. China 5 --- 5 --- 10 --- 10 --- 10 --- 10. Colombia ---(14) --- ---(14) --- 5(6) --- 10 --- 10 --- 11. Czech Republic 10 --- 10 --- 10 --- 10 --- 10 --- 12. Denmark 0(7) --- 15 --- 5(6) --- 15 --- 10 --- 13. Ecuador 5 --- 5 --- 10(6) --- 15 --- 10 --- 14. Estonia ---(15) --- ---(15) --- 4.9(6) --- 10 --- 10 --- 15. Finland ---(15) --- ---(15) --- 10(16) --- 10(17)/15 --- 10 --- 16. France 5(7)/15(18) --- ---(18) --- 15 5(19) 15 5(20)/10 15 10(21) 17. Germany 5(7) --- 15 --- 5(6) --- 10 ---- 10 --- 18. Greece 10 --- 10 --- 10 --- 10 --- 10 --- 19. Hong Kong(22) ---(15) --- ---(15) --- 4.9(23) --- 10 --- 10 --- 20. Hungary 5(1) --- 15 --- 10 --- 10 --- 10 --- 21. Iceland 5(7) --- 15 --- 10 --- 10 --- 10 --- 22. India 10 --- 10 --- 10 --- 10 --- 10 --- 23. Indonesia 10 --- 10 --- 10 --- 10 --- 10 --- 24. Ireland 5(7) --- 10 --- 5(6) --- 10 --- 10 --- 25. Israel 5(7)/10(18) --- 10 --- 10 --- 10 --- 10 --- 26. Italy 15 --- 15 --- 15 10(24) 15 10(24) 15 --- 27. Japan ---(25)/5(26) --- 15 --- 10(2) --- 10(3)/15 --- 10 --- 28. Korea 0(7) --- 15 --- 5(6) --- 15 --- 10 --- 29. Kuwait ---(15) --- ---(15) --- 4.9(6) --- 10 --- 10 --- 30. Latvia 5(7) --- 10 --- 5(6) --- 10 --- 10 --- 31. Lithuania 0(7) --- 15 --- 10 --- 10 --- 10 --- 32. Luxembourg 5(27)/8(28) --- 15 --- 10 --- 10 --- 10 --- 33. Netherlands 5(29) --- 15 --- 5(30) --- 5(31)/10 --- 10 --- 34. New Zealand 15 ---(32)/5(33) 15 --- 10 --- 10 --- 10 --- 35. Norway ---(34) --- 15 --- 10(6) --- 15 --- 10 --- 36. Panama 5(35) --- 7.5(36) --- 5(37) --- 10 --- 10 --- 37. Peru(38) 10(7) --- 15 --- 15 --- 15 --- 15 --- 38. Poland 5(7) --- 15 --- 10(30) --- 10(31)/15 --- 10 --- 39. Portugal 10 --- 10 --- 10 --- 10 --- 10 --- 40. Qatar ---(15) --- ---(15) --- 5(23) --- 10 --- 10 --- 41. Romania 10 --- 10 --- 15 --- 15 --- 15 --- 42. Russia 10 --- 10 --- 10 --- 10 --- 10 --- 43. Singapore ---(15) --- ---(15) --- 5(6) --- 15 --- 10 --- 44. Slovak Republic ---(15) --- ---(15) --- 10 --- 10 --- 10 --- 45. South Africa 5(1) --- 10 --- 10 --- 10 --- 10 --- 46. Spain 5(7) --- 15 --- 10(6) 5(39)/10(40) 15 5(41)/10(42) 10 --- 47. Sweden ---(15)/5(7) --- 15 --- 10(6) --- 15 --- 10 --- 48. Switzerland ---(43) --- 15 --- 5(30) --- 5(31)/10 --- 10 --- 49. Ukraine 5(7) --- 15 --- 10 --- 10 --- 10 --- 50. United Kingdom ---(43)/15(44) --- ---(43)/15(44) --- 5(16)/10(45) --- 5(46)/10(47)/15 --- 10 --- 51. United States ---(34)/5(7) --- 10 --- 4.9(16)/10(45) --- 4.9(46)/10(47)/15 --- 10 --- 52. Uruguay 5 --- 5 --- 10 --- 10 --- 10 ---





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5 Possibility of residence taxation.

6 See article 11, paragraph 2, subparagraph a) of the relevant Convention.

7 See article 10, paragraph 2, subparagraph a) of the relevant Convention.

8 See article 11, paragraph 3.

9 See paragraph 5 of the Protocol of the Convention between Mexico and Brazil, in relation to article 12, that is applicable regarding the aforesaid paragraph since January 1

st, 2007, by virtue of the Conveno entre o Governo da Repblica Federativa

do Brasil e o Governo da Repblica da frica do Sul para Evitar a Dupla Tributao e Prevenir a Evaso Fiscal em Relao aos Impostos sobre a Renda (For royalties other than those derived from industrial or commercial trademarks, including in relation to any income from technical assistance and technical services).

10 Ibidem. (For royalties derived from the use of industrial or commercial trademarks).

11 See paragraph 3 of the Protocol of the Convention between Mexico and Chile, in relation to article 11, that is applicable regarding the aforesaid paragraph since January 1

st, 2004, by virtue of the Convention between the Kingdom of Spain and the

Republic of Chile for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital (For interests derived from loans granted by banks or insurance companies).

12 Ibidem. (For interests derived from bonds or securities that are regularly and substantially traded on a recognized stock exchange and interests derived from sales on credit granted to the purchaser by the seller of machinery and equipment).

13 See paragraph 4 of the Protocol of the Convention between Mexico and Chile, in relation to article 12, that is applicable regarding the aforesaid paragraph since January 1

st, 2004, by virtue of the Convention between the Kingdom of Spain and the

Republic of Chile for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital.

14 See article 10, paragraph 1, in relation to paragraph 2 of the Protocol.

15 Residence taxation exclusively.

16 See article 11, paragraph 2, subparagraph a), section (i) of the relevant Convention.

17 See article 11, paragraph 2, subparagraph a), sections (i) and (ii).

18 See article 10, paragraph 2, subparagraph b).

19 See paragraph 6 of the Protocol of the Convention between Mexico and France, in relation to article 11, that is applicable regarding the aforesaid paragraph sucesively since September 21

st, 1992, by virtue of the Convention between Mexico and

Sweden; June 2nd

, 1994, by virtue of the Convention between Mexico and the United Kingdom; and October 22nd

, 1998, by virtue of the Convention between Mexico and Ireland (If the beneficial owner is a bank or an insurance institution).

20 Ibidem. (Interests derived from bonds or other securities that are regularly and substantially traded on a recognized stock exchange).

21 See paragraph 6 of the Protocol of the Convention between Mexico and France, in relation to article 12, that is applicable regarding the aforesaid paragraph since September 21

st, 1992, by virtue of the Convention between Mexico and Sweden.

22 Effective as of April 1st, 2014 in the Hong Kong Special Administrative Region.

23 See article 11, paragraph 2, section (a) of the relevant Convention.

24 See paragraph 6 of the Protocol of the Convention between Mexico and Italy, in relation to article 11, that is applicable regarding the aforesaid paragraph since December 27

th, 2001, by virtue of the Convention between Mexico and Luxembourg.

25 See article 10, paragraph 2, subparagraph (c).

26 See article 10, paragraph 2, subparagraph (b).

27 See article 10, paragraph 2, subparagraph a), section i).

28 See article 10, paragraph 2, subparagraph b), section i).

29 See article 10, paragraph 2, subparagraph a), in relation to paragraph X of the Protocol.

30 See article 11, paragraph 2, subparagraph a), section i) of the relevant Convention.

31 See article 11, paragraph 2, subparagraph a), section ii) of the relevant Convention.

32 See paragraph 9 of the Protocol of the Agreement between Mexico and New Zealand, in relation to article 10, that is applicable regarding the aforesaid paragraph since May 1

st, 2010, by virtue of the Convention between Australia and New

Zealand for the avoidance of double taxation with respect to taxes on income and fringe benefits and the prevention of fiscal evasion (No taxation if the beneficial owner is a company which holds at least 80% of the voting shares in the company paying the dividends during a period of 12 months, when the principal class of shares of the beneficial owner are listed on a recognized stock exchange or grant the right to receive equivalent benefits in respect of such dividends).

33 Ibidem. (If the beneficial owner is a company which owns at least 10 percent of the voting shares in the company paying the dividends).

34 See article 10, paragraph 3 of the relevant Convention.





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35

See article 10, paragraph 2, subparagraph a), in relation to paragraph 10, subparagraph H) of the Protocol. 36

See article 10, paragraph 2, subparagraph b), in relation to paragraph 10, subparagraph H) of the Protocol. 37

See article 11, paragraph 2, subparagraph a). 38

Effective as of January 1st, 2015. 39

See paragraph 4 of the Protocol of the Convention between Mexico and Spain, in relation to article 11, that is applicable regarding the aforesaid paragraph succesively since October 13

rd, 1994, by virtue of the Convention between Mexico and the

Netherlands; December 15th

, 1994 and December 15th

, 1997, by virtue of the Convention between Mexico and the United Kingdom, and December 22

nd, 1997, by virtue of the Convention between Mexico and Denmark (When the benefical owner is

a bank or an insurance institution). 40

Ibidem. (Regarding interests paid on loans of any kind granted by a bank or any other financial institution, including investment banks and savings banks and insurance companies. The 10% rate shall also be applicable if interests are paid by banks).

41 Ibidem. (Regarding interests derived from bonds and securities that are regularly and substantially traded on a recognized stock exchange).

42 Ibidem. (If interests are paid by the purchaser of machinery and equipment to a beneficial owner who is the seller of the machinery and equipment in connection with a sale on credit).

43 Source exemption.

44 See article 10, paragraphs 1 and 2, subparagraph b).

45 See article 11, paragraph 2, subparagraph b), section (i) of the relevant Convention.

46 See article 11, paragraph 2, subparagraph a), section (ii) of the relevant Convention.

47 See article 11, paragraph 2, subparagraph b), section (ii) of the relevant Convention.

Withholding Tax Rates Table

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