(Revenue Memorandum Circular No. 15-2016, Feb 15, 2016)
The RP-Germany Double Taxation Agreement (DTA) signed in 1983 has been renegotiated to take effect beginning January 1, 2016. The renegotiation lowered certain treaty rates as follows:
Dividends
- 5% if a stockholder owns at least 70 percent of company’s shares, from previous 10%.
- 10% in all other cases.
Interest
- 10% unless otherwise exempt, from 15%
- Interest for sales on credit of a commercial/scientific equipment and an enterprise to enterprise sale on credit, is now taxable only in the residence state of the creditor, and not anymore taxable at 10% in the source state.
Royalties
- Unified at 10% in lieu of the previous 10% or15%.
