國際稅項

一覽表

Withholding tax rates around the world Income master

Chart legend:
 

Treaty does not specify a rate: If a treaty does not specify a rate for a particular type of income, a rate of 25% is imposed by Canada and indicated below. Other rules may apply to payments arising in the other state.

Interest: The rates are those noted in a treaty for related-party interest. Effective 2008, Canadian withholding tax is eliminated on interest (except for "participating debt interest") paid to arm's length non-residents.

Dividend: If two or more rates are provided, the lower (lowest two in Vietnam) rate applies if the recipient is a company that owns/controls specified interest of the payor.

Estate or trust: Some treaties specify that the reduced withholding rate for:

  • trust income does not apply if contributions to the trust were deductible; and/or

  • estate or trust income applies only if the income is taxable in the recipient's country of residence.

If the rate indicated below for estate or trust income is 15% or 25%. the treaty specifies a 15% rate for trust income and no rate for estate income. In such cases, a rate of 15% may apply on estate income (rather that the maximum Canadian withholding tax rate of 25%) because in some circumstances a trust indicates an estate.

Lump sum pension: applicable to lump sum withdrawal from:

  • RPP

  • DPSP

  • RRSP

  • RRIF (amounts greater than 2x minimum or 10% of value at Jan 1)

  • withdrawal of commuted value from registered payout annuity at death
     

Periodic pension: applicable to annuity payments from registered source

  • RPP - scheduled payments

  • DPSP - scheduled payments

  • RRIF - 2x minimum or 10% of value at Jan 1, whichever is greater

  • Payout annuities - RPP, DPSP, RRSP scheduled payments
     

Lump sum annuity: applicable to the taxable portion of:

  • non-registered AA/IA if the annuitant was a non-resident at issue

  • non-registered payout annuity - commuted value
     

Periodic annuity: applicable to taxable portion of scheduled payments from non-registered payout annuity
 

Foreign income: applicable to foreign non-business income and foreign interest from non-registered foreign outside SPIO only
 

For payments from Canada:

* If the other state (Canada in the case of the treaty with Oman) concludes a treaty with another country providing a lower rate (higher rate in the case of Kenya), the lower rate (higher rate in the case of Kenya) will apply in respect of specific payments or with limits, in some cases.

** For the United States, the nil rate on interest applies between related persons, commencing 2010. The rate was 10% before 2008, 7% for 2008 and 4% for 2009. (These 7%, 4% and nil rates are subject to the Limitations of Benefits article.)

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