Changes to the treaty with this country include:
- reduction of the maximum dividend rate in the country of residence of the payer - from 15% to 10%;
- tightening the conditions for applying the minimum rate of 5% for dividends. This rate will be applied if the actual recipient of dividends is a company that owns at least 20% of the capital of the company that pays the dividends and (earlier - or) invested at least 100,000 euros in the acquisition of such capital;
- refinement of the provisions regarding the sale of movable property (Article 13 of the treaty).
The main changes are the following:
- increase in the maximum dividend rate in the country of residence of the payer - from 10% to 15%;
- interests will be taxed at a rate of 5% in the state in which they occur (now they are taxed only in the state the resident of which receives them);
- royalties will be taxed at a rate of 5% in the state in which they occur (now taxed only in the state, the resident of which receives them).