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Kazuiro Ebina
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International Tax and Transaction Services Leader
Ichiro Suto
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International Tax and Transaction Services – International Corporate Tax Advisory
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International Tax and Transaction Services – Transfer Pricing
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Tetsuya Bessho
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Yasuyuki Ogata
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International Tax and Transaction Services – International Capital Markets
Ichiro Suto
Global Compliance and Reporting
Toshikazu Shintani
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Koichi Sekiya
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Balazs Nagy
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Kenji Ueda
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Shinichiro Uzawa
Indirect Tax
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Yoichi Ohira Mobile: +81 (90) 5990-9629 Email: yoichi.ohira@jp.ey.com
Tax Technology and Transformation
Jun Hashimoto
Legal Services
Junzaburo Kiuchi
A. At a glance
Corporate Income Tax
Capital Gains Tax Rate
Branch Tax Rate
Withholding Tax
Dividends
Mobile: +81 (70) 7515-5247 Email: jun.hashimoto@jp.ey.com
Mobile: +81 (70) 3854-1004 Email: jb.kiuchi@jp.ey.com
23.2 (a)
23.2 (a)
23.2 (a)
(c)
15/20 (c)(d)
(c)
Operating
stated
(b) Except for the withholding taxes on royalties and certain interest (see footnote [d] below), these withholding taxes are imposed on both residents and non residents. For nonresidents, these are final taxes, unless the income is effec tively connected with a permanent establishment in Japan. Royalties paid to residents are not subject to withholding tax.
(c) Under the special law to secure funds for reconstruction related to the 11 March 2011 disasters, a special additional income tax (2.1% of the normal withholding tax due) is imposed for a 25-year period running from 1 January 2013 through 31 December 2037. As a result, the 20% withholding tax rate is increased to 20.42%, and the 15% rate is increased to 15.315%. However, this special additional income tax does not affect reduced withholding taxes under existing income tax treaties.
(d) Interest paid to residents on bonds, debentures or bank deposits is subject to a 20% withholding tax, which consists of a national tax of 15% and a local tax of 5%. Other interest paid to residents is not subject to a withholding tax. Interest paid to nonresidents on bonds, debentures or bank deposits is subject to a 15% withholding tax. Interest paid to nonresidents on national and local government bonds under the Book-Entry Transfer System is exempt from withholding tax if certain requirements are met.
(e) The loss carryback is temporarily suspended (see Section C).
B. Taxes on corporate income and gains
Corporate tax. Japanese domestic companies are subject to tax on their worldwide income, but nonresident companies pay taxes only on Japanese-source income. A domestic corporation is a corporation that is incorporated or has its head office in Japan. Japan does not use the “central management and control” criteria for determining the residence of a company.
Rates of corporate tax. The basic rate of national corporation tax is 23.2% for fiscal years beginning on or after 1 April 2018. For corporations with stated capital of JPY100 million or less, a tax rate of 15% applies to the first JPY8 million of taxable income. The tax rate of 15% applies for fiscal years beginning between 1 April 2012 and 31 March 2023.
Local income taxes, which are local inhabitant tax and enterprise tax, are also imposed on corporate income (see Section D). The resulting effective corporate income tax rate for companies sub ject to the 23.2% rate is approximately 35%. Under Business Scale Taxation (Gaikei Hyojun Kazei; see Section D), for certain corporations, the effective rate is reduced to approximately 31%.
Capital gains. In general, for Japanese corporate tax purposes, capital gains are not taxed separately. Such gains are treated as ordinary income to which normal tax rates apply. Transferor corporations in qualified reorganizations may defer the recogni tion of capital gains and losses arising in such transactions. Mergers, corporate spin-offs, share exchanges and contributions in kind are considered qualified reorganizations if they satisfy certain conditions.
A special surplus tax is imposed on capital gains from the sale of land located in Japan. However, this tax is suspended for sales conducted through 31 March 2023. The tax is calculated by applying the following rates, which vary depending on the length of time the property was held, to the capital gains.
Number of years held Rate Exceeding Not exceeding %
The 2009 tax reform introduced two temporary capital gains re liefs with respect to the holding of land investments. Under one of these measures, a special deduction of JPY10 million may be claimed with respect to capital gains arising from the sale of land acquired during the period from 1 January 2009 to 31 December 2010 and held for a period of five years or more, subject to cer tain conditions. The other measure is a capital gain deferral mechanism applicable to qualifying land acquired in the period from 1 January 2009 through 31 December 2010. This measure provides a deferral of 80% or 60% of the amount of capital gains arising from land disposed within a certain time period after the date on which the land is acquired, subject to certain conditions and filing obligations.
Administration. The tax year for a corporation is its fiscal year. A corporation must file a tax return within two months of the end of its fiscal year, paying the tax at that time. A one-month extension is normally available on application to the tax authorities. If cer tain conditions are met, a four-month extension is allowed. Except for newly established corporations, and corporations with a tax amount of JPY100,000 or less in the preceding year, if the fiscal year is longer than six months, the corporation must file an interim return within two months of the end of the first six months and make an advance payment at the time of filing the interim return equal to either 50% of its prior year’s tax liability or 100% of its estimated tax liability for the first six months of the current year.
Dividends received/paid. Dividends received from another domes tic corporation, net of any related interest expense incurred for acquisition of the shares, are generally excluded from gross in come. However, if the recipient corporation owns more than 5% and up to 331/3% of the domestic corporation distributing the dividends, 50% of the net dividend income is includible in gross income. If the recipient corporation owns 5% or less of the domes tic corporation distributing the dividends, 80% of the net dividend income is includable in gross income. Dividends distributed by a domestic corporation are subject to a 20% (20.42%, inclusive of the 2.1% special additional income tax) withholding tax.
A foreign dividend exemption system is available for Japanese companies holding a minimum interest of 25% for a period of at least six months before the date on which the decision to distrib ute the dividend is made. Under certain tax treaties, the minimum holding interest can be lower than 25%, subject to certain conditions. Under the foreign dividend exemption, 95% of foreign dividends received is excluded from taxable income. No credit for withholding tax or underlying tax on the foreign dividends is available.
If foreign dividends received by a domestic corporation are wholly or partially included as deductible expenses under the laws of the country where the headquarters of the foreign subsid iary is located, such foreign dividends are excluded from the foreign dividend exemption system. If a portion of the dividends that a domestic corporation receives from its foreign subsidiary are included as deductible expenses, the domestic corporation may elect to exclude only such portion from the foreign dividend exemption system (the domestic corporation is required to attach
prescribed statements to the tax return and preserve certain docu ments). Foreign tax credits are available for the amount of withholding taxes imposed on dividends that are excluded from the foreign dividend exemption system.
There is a special measure that was introduced to prevent tax avoidance by producing capital losses through the transfer of subsidiary shares following the receipt of nontaxable dividends from a subsidiary.
If an entity receives a certain amount of dividends from a subsid iary over which it has a certain degree of control and if the divi dends exceed an amount equivalent to 10% of the book value of such subsidiary shares, the reduction of the book value of those subsidiary shares by the amount of the dividends that are ex cluded from taxable income is required. The reduction of the book value decreases the amount of capital losses incurred at the time of subsidiary share transfer by an amount equivalent to the reduction in book value. “A certain degree of control” refers to a relationship in which the entity directly or indirectly owns more than 50% of shares of another entity.
However, exempted from this measure are cases in which the subsidiary is a domestic entity and 90% or more of its total shares from the time the subsidiary was incorporated to the time the control relationship was established were owned by domestic entities. This measure does not apply to cases in which total divi dends are less than the amount of net increase in the retained earnings of the subsidiary after the control relationship was estab lished and cases in which the dividends are received after 10 years since the control relationship was established. In addition, dividends of JPY20 million or less are not be subject to this measure.
Foreign tax credit. A Japanese company may be entitled to claim a foreign tax credit against both Japanese corporation tax and local inhabitant tax (see Section D). Creditable foreign income taxes for a Japanese company include foreign income taxes paid directly by a Japanese company and its foreign branches (direct tax credit). In addition, under tax treaties, a tax-sparing credit may be available to domestic companies with a branch or subsid iary in a developing country.
C. Determination of trading income
General. The tax law prescribes which adjustments to accounting income are required in computing taxable income. Expenditures incurred in the conduct of the business, except as otherwise pro vided by the law, are allowed as deductions from gross income.
Remuneration paid to directors cannot be deducted as an expense unless it is fixed compensation, remuneration determined and reported in advance or performance-based remuneration. The deductibility of entertainment expenses is restricted according to the size (capitalization) of the corporation (see Entertainment expenses). Deductions of donations, except for those to national or local governments or similar organizations, are limited.
Entertainment expenses. Entertainment expenses cannot be de ducted from taxable income. However, all corporations (corpora tions with stated capital in excess of JPY10 billion are excluded) may deduct 50% of entertainment expenses related to meal and
drink from taxable income for fiscal years beginning on or after 1 April 2014 until 31 March 2022. Small or medium-sized corporations can choose the 50% deduction or the fixed deduction of up to JPY8 million.
Inventories. A corporation may value inventory at cost under meth ods such as the following:
• Actual cost
• First-in, first-out (FIFO)
• Weighted average
Moving average
Most recent purchase
Retail
Alternatively, inventory may be valued at the lower of cost or market value. If a corporation fails to report the valuation method to the tax office, it is deemed to have adopted the most recent purchase price method.
Depreciation. The cost of tangible fixed assets, excluding land, may be recovered using statutory depreciation methods, such as straight-line or declining-balance. Depreciation rates are stipu lated in the Japanese tax law, which provides a range of rates for each asset category based on the useful life. Depreciation for tax purposes may not exceed the amount of depreciation recorded for accounting purposes. Revised depreciation rates apply to assets acquired on or after 1 April 2007. In addition, statutory salvage value and limit of depreciation are abolished in conjunction with the introduction of the revised depreciation rates. The following are the ranges of the revised depreciation rates for the straight-line and declining-balance methods for selected asset categories.
Declining-balance Asset category From To From To
Buildings
Building improvements
Straight-line
0.143 0.020
0.334 0.056
Other structures 0.334 0.013
—
Motor vehicles 0.500 0.050 1.000 0.100 Machinery and equipment 0.500 0.046 1.000 0.091
In the year of acquisition of specified machinery or equipment, a corporation may take additional depreciation. A corporation has the option of taking such additional depreciation or claiming the investment tax credit (see Investment tax credit).
Intangible assets, including goodwill, are amortized using the straight-line method over their useful lives. The useful life of goodwill is five years.
Investment tax credit. A specified small or medium-sized corpo ration that acquires or produces certain qualifying machinery or equipment (for use in its business within one year of acquisition) during the period of 1 June 1998 through 31 March 2023 may receive a credit against its corporate tax liability. The credit gener ally equals 7% of the cost or 20% of the corporate tax, which ever is less, and acts as a substitute for additional depreciation (see Depreciation).
Entities qualifying as specified business operators implementing 5G systems and certain other items (for example, radio transmitting facilities and switching facilities that are structured to cover whole telecommunication operation) in accordance with Certified Introduction Plans recognized under the Act to Promote the Spread of Specified Advanced Information Communication Systems that acquire and place into service certified equipment and facilities and other items (for example, production and con struction) in Japan between the period from 31 August 2020 and 31 March 2022 are eligible to elect between a 30% special depre ciation or 15% tax credit in relation to the acquisition cost. However, the credit is limited to 20% of the corporation tax amount in the applicable fiscal year.
For fiscal years beginning between 1 April 2021 and 31 March 2023, a corporation may claim a credit equal to 2% to 14% (12% to 17% for a small or medium-sized corporation) of total current research and development (R&D) expenditure, up to a maximum amount equal to 25% (in principle) of the corporate tax due for the relevant fiscal year. The maximum tax credit available to compa nies that have increased investment in R&D despite a decrease in sales above a certain level increases from 25% to 30% of corporate tax liability.
The general R&D tax credit limitation for certain startups that conduct R&D (that is, those that were established within the previous 10 years and that have net operating losses carried over into the next fiscal year) is 40% of corporate income tax liability in the applicable fiscal year.
If the R&D cost ratio (R&D costs ÷ average sales) is over 10%, a “top-up” measure can be applied to the gross-type credit maxi mum (25% of current year corporate tax). Depending on the R&D cost ratio (10% to 15%), the total cost incentive maximum may be increased to 35%.
In addition, tax credits relating to special open innovation R&D expenses (such as R&D expenses arising from joint research with special R&D institutions or universities) is available. The tax credit rate is 20%, 25% or 30% depending on the types of expenses. The maximum credit is 10% of corporation tax liabil ity in the applicable fiscal year.
If a business company or a person specified by the Minister of Economy, Trade and Industry as a stock company or other similar entity that engages in certain specified business activities jointly with a certain startup company invests in a startup company that meets certain criteria through the acquisition of shares in the startup company between the period 1 April 2020 to 31 March 2022, that company is allowed to deduct 25% or less of the acqui sition cost of the shares on the condition that it records that por tion in its own special account. The amount invested must be at least JPY100 million (or at least JPY500 million in the case of investment in a foreign entity). There is a limit on the amount invested to which the incentive applies.
If a business company or person applies this tax incentive and later transfers the shares or fulfills certain other criteria (for example, receives dividends in the case of the dissolution of corporation that issues certain shares), an amount stipulated in
relation to the corresponding criteria in the special account must be reversed and included in taxable income. However, this does not apply if the shares have been owned for a period of five years.
Tax credits for other investments in certain fields, such as job development and environmental operation, or specific facilities are also available for certain periods. Some of these credits apply to small or medium-sized corporations only.
A new tax incentive for digital transformation investment promotion was introduced by the 2021 tax reform. Companies that conduct digital transformation activities, such as cloud system implementations, which constitute digital capital investments to transform a business pursuant to a business plan approved by the national government, can choose between a 30% special depre ciation or a 3% tax credit (5% if sharing data with a non-group company) of the relevant acquisition costs. This is a temporary measure lasting two years. The maximum capital investment eli gible for this tax incentive is JPY30 billion.
Under a new tax incentive introduced by the 2021 tax reform, companies that invest in facilities and equipment contributing to the reduction of greenhouse gas emissions pursuant to a business plan approved by the national government may choose between a 50% special depreciation or a tax credit of 5% (10% if certain requirements are fulfilled) of the relevant acquisition costs. This is a temporary measure lasting three years. However, if this tax credit is used together with the tax credit offered by the digital transformation investment promotion tax incentive, the total tax credit is capped at 20% of corporate tax liability for a relevant fiscal year. The maximum facility or equipment investment amount eligible for this tax incentive is JPY50 billion.
Net operating losses. Net operating losses of certain corporations may be carried forward for 10 years (9 years for losses arising until 31 March 2018), and may be carried back 1 year. Except for certain small or medium-sized corporations, the deductible amount is limited to 50% of taxable income. The loss carryback is suspended for fiscal years ending from 1 April 1992 through 31 March 2022. However, this suspension does not apply to specified small or medium-sized corporations.
Groups of companies. The Consolidated Tax Return System (CTRS) applies to a domestic parent corporation and its 100% domestic subsidiaries. A consolidated group must elect the appli cation of the CTRS, subject to the approval of the National Tax Agency (NTA). If a consolidated group wants to terminate its CTRS election, it must obtain the approval of the NTA.
Replacing the current consolidated taxation regime, a new group income and loss-sharing regime was introduced by the 2020 tax reform and is applicable to fiscal years beginning on or after 1 April 2022. The new regime maintains the basic framework of the current consolidated taxation regime (for example, the offset ting of profits and losses) while also reflecting the consideration given to reducing the administrative workload of companies. The
design of a new regime that is better aligned with the tax rules governing corporate reorganizations, in terms of market value taxation and the restriction on utilization of net operating losses on an initial tax consolidation or entry into an existing tax group, will reduce both the number of entities subject to market value taxation and the number of entities subject to the restriction on the utilization of net operating losses.
Corporate tax law also contains special taxation for intragroup transactions in 100% groups, under which certain gains and losses are tax deferred. This taxation is separate from the CTRS or the new group income and loss-sharing regime.
D. Other significant taxes
The following table summarizes other significant taxes.
Nature of tax Rate
Consumption tax; on a broad range of goods and services 10%
Enterprise tax
Companies that are subject to Business Scale Taxation; Business Scale Taxation (Gaikei Hyojun Kazei) applies to companies with stated capital of more than JPY100 million; under Business Scale Taxation, a company is subject to tax on the basis of its added value, its capital amount and its taxable income Rate on added value 1.26% Rate on capital amount 0.525% Rates on taxable income
0.4% to 1.18% Companies that are not subject to Business Scale Taxation; rates applied to taxable income
3.5% to 7.48%
Special enterprise tax; a national tax, which is levied on companies that are subject to enterprise tax; imposed on local enterprise tax liability with respect to taxable income Companies subject to business scale enterprise tax 260% Companies not subject to business scale enterprise tax 37%
Local inhabitant tax, which consists of an income levy and a capital levy Income levy; computed as a percentage of national income tax; rate depends on the company’s capitalization and amount of national income tax
Capital levy; based on the company’s capitalization and number of employees; annual assessments vary depending on the cities and prefectures in which the company’s offices are located
7.0% to 10.4%
JPY70,000 to JPY3,800,000
Nature of tax Rate
Local corporate tax; a national tax, imposed on standard corporate tax liability 10.3% Social insurance contributions, on monthly standard remuneration and bonuses
Basic contribution, paid by
Employer 14.97%
Employee 14.37%
Nursing insurance premium for employees who are age 40 or older, paid by Employer 0.90% Employee 0.90%
E. Miscellaneous matters
Foreign-exchange controls. The Bank of Japan controls inbound and outbound investments and transfers of money. Effective from 1 April 1998, the reporting requirements were simplified.
Transfer pricing. The transfer-pricing law stipulates that pricing between internationally affiliated entities should be determined at arm’s length. Entities are considered to be internationally af filiated entities if a direct or indirect relationship involving 50% or more ownership or substantial control exists. The law provides that the burden of proof as to the reasonableness of the pricing is passed to the taxpayer, and if the taxpayer fails to provide proof or to disclose pertinent information to the tax authorities, taxable income is increased at the discretion of the tax authorities. The 2011 revision of the law eliminated the hierarchy-based selection of transfer-pricing methods and allows the selection of the most appropriate transfer-pricing method in each specific case.
Under the 2019 tax reform, the discounted cash flow recognized under the Organisation for Economic Co-operation and Development (OECD) Transfer Pricing Guidelines was added as a new transfer-pricing methodology.
It is possible to apply for advance-pricing arrangements with the tax authorities. In cases in which a taxpayer has received a transferpricing assessment as a result of an examination, a taxpayer ap plying for a Mutual Agreement Procedure between Japan and the relevant treaty partner country may be granted a grace period for the payment of taxes due by assessment, including penalty taxes. The length of the grace period depends on the specific circum stances of the assessment.
Controlled foreign companies. The special provisions of income tax related to specified foreign subsidiaries of Japanese domestic companies (so-called “foreign subsidiary income inclusion taxa tion”) are the Japanese equivalent to most jurisdictions’ con trolled foreign company (CFC) rules.
If a Japanese domestic company (including individuals who have a special relationship with a Japanese domestic company) owns 10% or more of the issued shares of a foreign related company of which more than 50% is owned directly or indirectly by Japanese domestic companies and Japanese resident individuals (including nonresident individuals who have a special relationship with Japanese domestic companies or Japanese resident individuals),
the income of the foreign related company must be included in the Japanese parent company’s taxable income in proportion to the equity held. Losses of a foreign related company may not offset the taxable income of the Japanese parent company. To avoid double taxation, a Japanese company can claim a foreign tax credit on the corporate income tax paid by a foreign related company that is subject to CFC income inclusion.
Determination of foreign entities subject to income inclusion. The indirect ownership ratio for the determination of a foreign related company that is subject to income inclusion is calculated based on the equity ratio of a foreign entity with a chain relation ship with a domestic company through the ownership of more than 50% of equity. If there is a relationship between a resident or Japanese domestic company and a foreign entity in which the resident or Japanese domestic company is able to make claim to basically all of the foreign entity’s residual property, the foreign entity is included in the scope of foreign related companies and the resident or Japanese domestic company is subject to income inclusion.
Income inclusion taxation on an entity-wide basis. The foreign related companies that do not satisfy any of the economic activity criteria (business criteria, substance criteria, control criteria and location or unrelated party criteria) are subject to income inclusion on an entity-wide basis. If the tax liability ratio of a foreign related company’s fiscal year is 20% or more, the company is exempt from the application of income inclusion on an entity-wide basis. The tax liability ratio is calculated on a company-by-company basis.
Partial income inclusion rules for certain income. Foreign related companies that fulfill all of the economic activity criteria are subject to partial income (passive income) inclusion. The follow ing types of income are subject to partial income inclusion:
• Interest
• Dividends
• Consideration for securities lending, and capital gains or losses on securities
• Gains or losses from derivative trading
• Gains or losses from foreign exchange
• Consideration for the lease of tangible fixed assets
• Royalties from intangible assets
• Capital gains or losses from intangible assets and other assets
If the tax liability ratio of a foreign related company’s fiscal year is 20% or more, the foreign related company is exempt from the application of partial income inclusion. The materiality threshold related to partial income inclusion is JPY20 million or less; that is, the foreign related company is exempt if its partial income inclusion is JPY20 million or less.
Income inclusion on an entity-wide basis for certain foreign related companies. Paper companies, cashbox companies and prohibited list territory companies are subject to income inclusion on an entity-wide basis. If the tax liability ratio of a foreign related company mentioned above is 30% or more for the fiscal year, the company is exempt from the application of income inclusion on an entity-wide basis.
Dividends distributed by a foreign related company cannot gen erally be excluded from the income inclusion added back to the Japanese parent company’s taxable income. However, the follow ing dividends received by a foreign related company can be excluded from the apportionment to the Japanese parent compa ny’s income:
• Dividends from a foreign subsidiary in which the foreign related company has held 25% or more of the total issued shares or the total voting shares for a period of at least six months. The equity ratio requirement relating to dividends excluded from the inclu sion amount is 10% or more for dividends received from foreign subsidiaries whose primary business is the extraction of crude oil, oil gas, combustible natural gas or coal (collectively, fossil fuels), including businesses closely related to such extracted fossil fuels, and that possess an extraction site in a jurisdiction that has entered into a tax treaty with Japan.
• Dividends that have already been added to the Japanese parent company’s taxable income as another foreign related company’s income under the foreign subsidiary income inclusion taxation rules
The 2019 tax reform clarifies that local tax laws of the foreign related companies, such as those relating to tax consolidation and distributive share of partnership income, are disregarded in deter mining the tax liability ratio test, income inclusion or indirect foreign tax credit with respect to foreign related companies.
Debt-to-equity rules. Thin-capitalization rules limit the deduction for interest expense for companies with foreign related-party debt if the debt-to-equity ratio exceeds 3:1.
Earnings-stripping rules. Earnings-stripping rules limit the de ductibility of interest paid by corporations to foreign related persons. Net interest paid to foreign related persons by a corpora tion in excess of 20% of its adjusted taxable income is disallowed as a tax deduction. Interest deductions disallowed under this provision are carried forward for up to seven years. If earningsstripping rules and thin-capitalization rules both apply, the rule that results in a larger disallowance is applied.
F. Treaty withholding tax rates
For treaty jurisdictions, the rates reflect the lower of the treaty rate and the rate under domestic tax laws on outbound payments.
Dividends Interest Royalties
%
Australia
%
0/5/10 (m) 0/10 (c) 5
Austria 0/10 (ff) 0 0
Bangladesh 10/15 (a) 10 (c) 10
Belgium 0/10 (ee) 0/10 (pp) 0
Brazil 12.5 12.5 (c) 12.5/15/20 (f)
Brunei
Darussalam
5/10 (l) 10 (c) 10
Bulgaria 10/15 (a) 10 (c) 10
Canada 5/15 (a) 10 (c) 10
Chile 0/5/15 (ii) 4/10 (jj) 2/10 (kk)
China Mainland 10 10 (c) 10
Croatia 0/5 (qq) 0/5 (rr) 5
Dividends Interest Royalties % % %
Czechoslovakia (n) 10/15 (a) 10 (c) 0/10 (i)
Denmark 0/15 (hh) 0 0
Egypt 15 15/20 (q) 15
Estonia 0/10 (mm) 0/10 (mm) 5
Finland 10/15 (a) 10 10
France 0/5/10 (u) 10 (c) 0
Germany 0/5/15 (d) 0 0
Hong Kong SAR 5/10 (l) 10 (c) 5
Hungary 10 10 (c) 0/10 (i)
Iceland 0/5/15 (nn) 0 0
India 10 10 (c) 10
Indonesia 10/15 (a) 10 (c) 10
Ireland 10/15 (a) 10 10
Israel 5/15 (a) 10 (c) 10
Italy 10/15 (a) 10 10 Jamaica 5/10 (ss) 0/10 (r) 2/10 (tt)
Kazakhstan 5/15 (a) 10 (c) 5 (w)
Korea (South) 5/15 (a) 10 (c) 10
Kuwait 5/10 (l) 10 (c) 10
Latvia 0/10 (ll) 0/10 (ll) 0
Lithuania 0/10 (ll) 0/10 (ll) 0
Luxembourg 5/15 (a) 10 (c) 10
Malaysia 5/15 (a) 10 (c) 10
Mexico 0/5/15 (o) 10/15 (c)(p) 10
Netherlands 0/5/10 (y) 10 (z) 0 (aa)
New Zealand 0/15 (x) 10 (c) 5
Norway 5/15 (a) 10 (c) 10
Oman 5/10 (l) 10 (c) 10
Pakistan 5/7.5/10 (v) 10 (c) 10
Peru 10 0/10 (c) 15
Philippines 10/15 (l) 10 (c) 10 (g)
Poland 10 10 (c) 0/10 (i)
Portugal 5/10 (l) 10 (cc) 5
Qatar 5/10 (l) 10 (c) 5
Romania 10 10 (c) 10/15 (i)
Russia Federation 0/5/10/15 (gg) 0 0
Saudi Arabia 5/10 (l) 10 (c) 5/10 (r)
Serbia 5/10 (ss) 0/10 (pp) 5/10 (ww)
Singapore 5/15 (a) 10 (c) 10
Slovenia 5 0/5 (c) 5
South Africa 5/15 (a) 10 (c) 10
Spain 0/5 (oo) 0 0
Sri Lanka 20 15/20 (c)(q) 0/10 (h)
Sweden 0/10 (t) 0 (dd) 0 (aa)
Switzerland 0/5/10 (y) 10 (z) 0 (aa)
Thailand 15/20 (s) 10/15/20 (c)(j)(q) 15
Turkey 10/15 (a) 10/15 (c)(j) 10
USSR (k) 15 10 (c) 0/10 (i)
United Arab Emirates 5/10 (l) 10 (c) 10
United Kingdom 0/10 (t) 0 (dd) 0 (aa)
United States 0/5/10 (b) 0 (bb) 0
Uruguay 5/10 (vv) 0/10 (z) 10
Uzbekistan