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 (%)

Country
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
32.
33.
34.
35.
36.
37.
38.
39.
40.
41.
42.
43.
44.
45.
46.
47.
48.
49.
50.
51.
52.

Australia
Austria
Bahrain
Barbados
Belgium
Brazil
Canada
Chile
China
Colombia
Czech Republic
Denmark
Ecuador
Estonia
Finland
France
Germany
Greece
Hong Kong(22)
Hungary
Iceland
India
Indonesia
Ireland
Israel
Italy
Japan
Korea
Kuwait
Latvia
Lithuania
Luxembourg
Netherlands
New Zealand
Norway
Panama
Peru(38)
Poland
Portugal
Qatar
Romania
Russia
Singapore
Slovak Republic
South Africa
Spain
Sweden
Switzerland
Ukraine
United Kingdom
United States
Uruguay

Substantial
shareholding
0(1)
5(4)
---(5)
5(7)
5(7)
10(7)
5(7)
5(7)
5
---(14)
10
0(7)
5
---(15)
---(15)
5(7)/15(18)
5(7)
10
---(15)
5(1)
5(7)
10
10
5(7)
5(7)/10(18)
15
---(25)/5(26)
0(7)
---(15)
5(7)
0(7)
5(27)/8(28)
5(29)
15
---(34)
5(35)
10(7)
5(7)
10
---(15)
10
10
---(15)
---(15)
5(1)
5(7)
---(15)/5(7)
---(43)
5(7)
---(43)/15(44)
---(34)/5(7)
5

Dividends
MFN
General
---------------------------------------------------------------------(32)/5(33)
-------------------------------------

15
10
---(5)
10
15
15
15
10
5
---(14)
10
15
5
---(15)
---(15)
---(18)
15
10
---(15)
15
15
10
10
10
10
15
15
15
---(15)
10
15
15
15
15
15
7.5(36)
15
15
10
---(15)
10
10
---(15)
---(15)
10
15
15
15
15
---(43)/15(44)
10
5

MFN
---------------------------------------------------------------------------------------------------------

Financial
Sector
10(2)
10
4.9(6)
10
10(8)
15
10
15
10
5(6)
10
5(6)
10(6)
4.9(6)
10(16)
15
5(6)
10
4.9(23)
10
10
10
10
5(6)
10
15
10(2)
5(6)
4.9(6)
5(6)
10
10
5(30)
10
10(6)
5(37)
15
10(30)
10
5(23)
15
10
5(6)
10
10
10(6)
10(6)
5(30)
10
5(16)/10(45)
(16)
4.9 /10(45)
10

MFN

Interests
General

--------------5(11)
--------------5(19)
------------------10(24)
--------------------------------------5(39)/10(40)
-------------

10(3)/15
10
10
10
15
15
10
15
10
10
10
15
15
10
10(17)/15
15
10
10
10
10
10
10
10
10
10
15
(3)
10 /15
15
10
10
10
10
(31)
5 /10
10
15
10
15
10(31)/15
10
10
15
10
15
10
10
15
15
5(31)/10
10
5(46)/10(47)/15
(46)
4.9 /10(47)/15
10

MFN
--------------10(12)
--------------(20)
5 /10
-------------------10(24)
--------------------------------------5(41)/10(42)
-------------

Royalties
General
MFN
10
10
10
10
10
15
10
15
10
10
10
10
10
10
10
15
10
10
10
10
10
10
10
10
10
15
10
10
10
10
10
10
10
10
10
10
15
10
10
10
15
10
10
10
10
10
10
10
10
10
10
10

----------(9)
10 /15(10)
--10(13)
--------------10(21)
-------------------------------------------------------------------------

MFN: Most favoured nation.

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

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).
2

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
2

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

Possibility of residence taxation.

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
st
regarding the aforesaid paragraph since January 1 , 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
st
regarding the aforesaid paragraph since January 1 , 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
st
regarding the aforesaid paragraph since January 1 , 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
st
regarding the aforesaid paragraph sucesively since September 21 , 1992, by virtue of the Convention between Mexico and
nd
nd
Sweden; June 2 , 1994, by virtue of the Convention between Mexico and the United Kingdom; and October 22 , 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
st
regarding the aforesaid paragraph since September 21 , 1992, by virtue of the Convention between Mexico and Sweden.
22
st
Effective as of April 1 , 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
th
regarding the aforesaid paragraph since December 27 , 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
st
applicable regarding the aforesaid paragraph since May 1 , 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.
6

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
3

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

35

See article 10, paragraph 2, subparagraph a), in relation to paragraph 10, subparagraph H) of the Protocol.
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
st
Effective as of January 1 , 2015.
39
See paragraph 4 of the Protocol of the Convention between Mexico and Spain, in relation to article 11, that is applicable
rd
regarding the aforesaid paragraph succesively since October 13 , 1994, by virtue of the Convention between Mexico and the
th
th
Netherlands; December 15 , 1994 and December 15 , 1997, by virtue of the Convention between Mexico and the United
nd
Kingdom, and December 22 , 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.
36

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
4