Withholding Tax Rates for Royalties |
under
Thailand's DTAs |
if the
recipient of royalties does not have a P.E. or fixed base in the source
country |
Country | Tax
Rate not exceeding | Types
of Royalties |
|
|
1. Germany | 5 | use
of or the right to use any copyright of literary, artistic or scientific work |
| 15 | other
royalties |
| | Note
: also apply to the gains from the alienation of any right or property |
| | giving
rise to such royalties if such right or property is alienated by a |
| | resident
of a Contracting State for exclusive use in the other Contracting |
| | State
and the payment of such right or property is borne by an enterprise |
| | of
that other State or a permanent establishment situated therein |
| | |
2. France | 5 | alienation
or use of or the right to use any copyright of literary, artistic or |
| | scientific
work |
| 15 | other
royalties |
| Exempt | royalties
or other like payments payable to a Contracting State or a |
| | State
owned company in respect of films or tapes |
| 10 | as long as the tax rate provided by the French law on the
royalties |
| | received by a French resident as consideration for the
alienation of, |
| | or the exclusive right to use any patent, process or
information |
| | concerning industrial experience does not exceed 10 per
cent, |
| | the tax charged in the Contracting State in which such
royalties arise |
| | shall not exceed 10 per cent. |
| | |
3. Singapore | 15 | all
royalties |
| | |
4. Netherlands | 5 | use
of or the right to use any copyright of literary, artistic or scientific work |
| 15 | other
royalties |
| | |
5. Italy | 5 | use
of or the right to use any copyright of literary, artistic or scientific work |
| 15 | other
royalties |
| | |
6. Belgium | 5 | use
of or the right to use any copyright of literary, artistic or scientific work |
| 15 | other
royalties |
| | |
7. Pakistan | 10 | alienation
or use or the right to use any copyright of literary, artistic |
| | or
scientific work |
| 20 | other
royalties (Note: For royalties
arising in Thailand, apply 15% in |
| | accordance
with the Revenue Code) |
| Exempt | royalties
or other like payments payable to a Contracting State or a |
| | State
owned company in respect of films or tapes |
| | |
8. United Kingdom | 5 | use
of or the right to use any copyright of literary, artistic or scientific work |
| 15 | other
royalties |
| | |
9. Malaysia | 15 | all
royalties except any royalty or other amount paid in respect of |
| | motion
picture films or of tapes for
radio or television broadcasting, or |
| | of
the operation of a mine, oil
well, quarry or any other
place of |
| | extraction
of natural resources or of timber or other forest produce |
| Exempt | approved
industrial royalties derived from Malaysia by a resident of |
| in Malaysia | Thailand |
| | |
10. Philippines | 15 | if
the royalties are paid |
| | (1)
by an enterprise registered with the
Philippine Board of |
| | Investments and engaged in
preferred areas of activities; or |
| | (2)
by an enterprise under the promotion of the Board of Investment |
| | of Thailand; or |
| | (3)
in respect of cinematographic films or tapes for television or |
| | broadcasting |
| 25 | other
royalties (Note: For royalties arising in Thailand, apply 15% in |
| | accordance
with the Revenue Code) |
| | |
11. Poland | 5 | alienation,
use of or the right to use any copyright of literary, artistic or |
| | scientific
work excluding cinematographic films or tapes for television |
| | or
broadcasting |
| 15 | other
royalties |
| Exempt | royalties
or other like payments payable to a Contracting State or a |
| | State
owned company in respect of films or tapes |
| | |
12. Canada | 5 | copyright
royalties and other like payments in respect of the production |
| | or
reproduction of any literary, dramatic, musical or artistic work (but
not |
| | including
royalties in respect of motion picture films and works on film |
| | or
videotape for use in connection with television) |
| | (alienation,
the use of, or the right to use) |
| 15 | all
royalties |
| | |
13. Finland | 15 | all
royalties |
| | |
14. India | 15 | all
royalties |
| | |
15. Austria | 15 | all
royalties |
| | |
16. China | 15 | all
royalties |
| | |
17. Sweden | 15 | all
royalties |
| | |
18. Hungary | 15 | all
royalties |
| | |
19. Australia | 15 | all
royalties |
| | |
20. Sri Lanka | 15 | all
royalties |
| | |
21. Japan | 15 | all
royalties |
| | |
22. Vietnam | 15 | all
royalties |
| | |
23. Czech Republic | 5 | alienation
or use of or the right to use any copyright of literary, artistic or |
| | scientific
work, excluding cinematograph films or films or tapes used for |
| | radio
or television broadcasting |
| 10 | alienation
of any patent, trademark, design or model, plan, secret |
| | formula
or process |
| 15 | other
royalties |
| | |
24. Switzerland | 5 | alienation
or use of, or the right to use any copyright, artistic or scientific |
| | work,
excluding cinematograph films or films or tapes used for radio or |
| | television
broadcasting |
| 10 | alienation
of any patent, trade mark, design or model, plan, secret |
| | formula
or process |
| 15 | other
royalties (However, Thailand shall tax at the rate not exceeding 10 |
| | percent
if Switzerland does not, according to its internal law, levy a tax |
| | at
source on royalties paid to non-residents and for tax credit purposes, |
| | allows
as a deductible expense 50 per cent of the gross amount of |
| | royalties |
| | |
25. Israel | 5 | use
of or the right to use any copyright of literary, artistic or scientific work |
| | excluding
cinematograph films or films or tapes used for radio or |
| | television
broadcasting |
| 15 | other
royalties |
| | |
26. South Africa | 15 | all
royalties |
| | |
27. Romania | 15 | all
royalties |
| | |
28. United States of
America | 5 | use
of or the right to use any copyright of literary, artistic or scientific work |
| | including
software, and motion pictures and works on film, tapes or |
| | other
means of reproduction for use in connection with radio or |
| | television
broadcasting |
| 8 | use
of or the right to use industrial, commercial or industrial equipment |
| 15 | other
royalties |
| | |
29. Laos | 15 | all
royalties |
| | |
30. Mauritius | 5 | use
of or the right to use any copyright of literary, artistic or scientific work |
| | excluding
cinematograph films and films, tapes or discs used for radio |
| | or
television broadcasting |
| 15 | other
royalties |
| | |
31. Luxembourg | 15 | all
royalties |
| | |
32. Bangladesh | 15 | all
royalties |
| | |
33. Nepal | 15 | all
royalties |
| | |
34. Spain | 5 | use
of, or the right to use, any
copyrights of literary, dramatic, musical |
| | artistic
or scientific work, excluding cinematograph films or films or |
| | tapes
used for radio or television broadcasting |
| 8 | financial
leasing for the use of, or the right to use, industrial, commercial |
| | or
scientific equipment |
| 15 | other
royalties |
| | |
35. New Zealand | 10 | use
of or the right to use any copyright, any industrial, commercial or |
| | scientific
equipment, any motion picure film or film or videotape or any |
| | other
recording for use in connection with television, or tape or any other |
| | recording
in connection with radio broadcasting; the reception of, or the |
| | right
to receive, visual images or sounds or both & the use in connection |
| | with
television or radio broadcasting, visual images or sounds, or both, |
| | transmitted
by satellite or cable, optic fibre or similar technology |
| 15 | other
royalties |
| | |
36. Denmark | 5 | use or the right to use any copyright of literary, artistic
or scientific work |
| 15 | other
royalties |
| | |
37. Uzbekistan | 15 | all
royalties |
| | |
38. Cyprus | 5 | use
of or the right to use any copyright of literary, dramatic, musical, |
| | artistic
or scientific work, including software, cinematograph films or |
| | or
tapes used for radio or television broadcasting |
| 10 | use
of, or the right to use, industrial, commercial or scientific equipment |
| | or
for information concerning industrial, commercial or scientific |
| | experience |
| 15 | other
royalties |
| | |
39. United Arab Emrates | 15 | all
royalties |
| | |
40. Bulgaria | 5 | use
or the right to use any copyright of literary, artistic or scientific work |
| | excluding
cinematography films and films, tapes or discs for radio or |
| | television
broadcasting |
| 15 | other
royalties |
| | |
41. Armenia | 15 | all
royalties |
| | |
42. Indonesia | 15 | all
royalties |
| | |
43. Norway | 5 | use
or the right to use any copyright of literary, artistic or scientific work |
| 10 | use
or the right to use industrial, commercial or scientific equipment |
| 15 | other
royalties |
| | |
44. Bahrain | 15 | all
royalties |
| | |
45. Oman | 15 | all
royalties |
| | |
46. Slovenia | 10 | use
of or the right to use any copyright of literary, artistic or scientific work |
| | including
motion pictures, live broadcasting, film, tape or other means |
| | of
the use or reproduction in connection with radio and television |
| | broadcasting,
and for the use of, or the right to use industrial, |
| | commercial
or scientific equipment |
| 15 | other
royalties |
| | |
47. Ukraine | 15 | all
royalties |
| | |
48. Turkey | 15 | all
royalties |
| | |
49. Hong Kong | 5 | use
of, or the right to use, any copyright of literary, artistic or scientific |
| | work |
| 10 | use
of, or the right to use, any patent, trademark, design or model, plan, |
| | secret
formula or process |
| 15 | other
royalties |
| | |
50. Seychelles | 15 | all
royalties |
| | |
51. Kuwait | 20 | all
royalties (Note: For royalties arising in Thailand, apply 15% in |
| | accordance
with the Revenue Code) |
| | |
52. Korea | 5 | use
of, or the right to use, any copyright of literary, artistic or scientific |
| | work |
| 10 | use
of, or the right to use, any patent, trademark, design or model, plan, |
| | secret
formula or process |
| 15 | other
royalties |
| | |
53. Russian | 15 | all royalties |
| | |
54. Chile | 10 | use of or the right to use any copyright of literary, artistic or |
| | scientific work, or use of or the right to use industrial, commercial or |
| | scientific equipment |
| 15 | other
royalties |
| | |
55. Myanmar | 5 | use of, or the right to use, any copyrights of literary, artistic or scientific work |
| 10 | the consideration for any services of a managerial or consultancy nature, |
| | or for information concerning industrial, commercial, or scientific experience
|
| 15 | all other cases |
| | |
56. Chinese Taipei | 10 | All royalties |
| | |