(dividends, royalty, interest)
Dividends distributed to non-transparent entities owning at least 10% of the share capital are not subject to withholding tax. If the recipient qualifies as a conduit company, or ownership is less than 10% withheld tax applies.
Dividends does not constitutes as a deductible expense for the distributor.
Royalty is – as a rule – subject to withhold tax of 22%. However, in many cases the percentage will be reduced or even waived according to entered tax treaty or EU royalty directive.
Royalty is a deductible expense for the distributor.
Interest is as a rule not subject to withhold tax. However, if recipient company is incorporated within EU but qualifies as a conduit company and beneficial owner is situated in a jurisdiction without a tax treaty (tax heaven) 22% withhold tax applies.
Interest is generally considered as a deductible expense for the distributor. However, regulation to avoid tax erosion due to thin capitalization is applicable.