Czech corporations are required to withhold tax on payments of dividends, interest, and royalties as follows (please note that this overview is indicative only and cannot be relied upon without checking the particular DTT, as each DTT has its own definition of dividends, interest, and royalties):

RecipientWHT (%)
Dividend (1)Interest (2)Royalties (3)
Resident corporations1500
Resident individuals1500
    
Non-resident corporations and individuals:   
Non-treaty15/3515/3515/35
Treaty:   
Albania5/150/510
Andorra5/1005/10
Armenia100/5/105/10
Australia5/151010
Austria0/1000/5
Azerbaijan80/5/1010
Bahrain5010
Bangladesh10/150/1010
Barbados5/150/55/10
Belarus5/100/55
Belgium5/150/100/5
Bosnia500/10
Botswana50/7.57.5
Brazil150/10/1515/25
Bulgaria100/1010
Canada5/150/1010
Chile154/105/10
China, People’s Republic of5/100/7.510
Colombia5/15/250/1010
Croatia5010
Cyprus0/500/10
Democratic People’s Republic of Korea100/1010
Denmark0/1500/10
Egypt5/150/1515
Estonia5/150/1010
Ethiopia100/1010
Finland5/1500/1/5/10
France0/1000/5/10
Georgia5/100/80/5/10
Germany5/1505
Ghana60/108
GreeceLocal rates0/100/10
Hong Kong5010
Hungary5/15010
Iceland5/15010
India100/1010
Indonesia10/150/12.512.5
Iran50/58
Ireland, Republic of5/15010
Israel5/150/105
Italy1500/5
Japan10/150/100/10
Jordan100/1010
Kazakhstan100/1010
Korea, Republic of50/50/10
Kosovo5/1500/10
Kuwait0/5010
Kyrgyzstan 5/100/510
Latvia5/150/1010
Lebanon505/10
Liechtenstein0/1500/10
Lithuania5/150/1010
Luxembourg0/1000/10
Macedonia5/15010
Malaysia100/1212
Malta505
Mexico100/1010
Moldova5/15510
Mongolia100/1010
Morocco100/1010
Netherlands0/1005
New Zealand150/1010
Nigeria12.5/150/1515
Norway0/1500/5/10
Pakistan5/150/1010
Panama100/5/1010
Philippines10/150/1010/15
Poland50/510
Portugal10/150/1010
Qatar0/5/10010
Romania100/710
Russia (6)SuspendedSuspendedSuspended
San Marino100/1010
Saudi Arabia5010
Senegal5/100/1010
Serbia and Montenegro100/105/10
Singapore500/5/10
Slovak Republic5/1500/10
Slovenia5/150/510
South Africa5/15010
Spain5/1500/5
Sri Lanka150/100/10
Sweden0/1000/5
Switzerland0/1505 (4)/10
Syria100/1012
Taiwan (5)100/105/10
Tajikistan50/710
Thailand100/105/10/15
Tunisia10/15125/15
Turkey100/1010
Turkmenistan100/1010
Ukraine5/150/510
United Arab Emirates0/5010
United Kingdom5/1500/10
United States5/1500/10
Uzbekistan5/100/510
Venezuela5/100/1012
Vietnam100/1010

Notes

General note: The WHT rates stipulated by the relevant DTT can, in most cases, be applied by the Czech tax-resident corporation without the need to seek for a pre-approval or similar procedure with the Czech tax authorities. The Czech corporation must be prepared the prove to Czech tax authorities that the DTT provisions were applied correctly; usually the minimum requirement for the Czech corporation is to have available the tax residency certificate of the non-resident recipient of the income and confirmation that the recipient is the beneficial owner of the respective income.

The general WHT rate for dividends is 15% (35% for dividends paid to residents of non-EU and non-EEA countries with which the Czech Republic does not have an enforceable DTT or TIEA in place). If the DTT provides for two rates, the lower rate usually applies if the recipient of the dividends is a company that directly owns at least a certain amount of the capital or a certain amount of the voting shares of the company paying the dividend.

The general WHT rate for interest paid to non-residents is 15% (35% for interest paid to residents of non-EU and non-EEA countries with which the Czech Republic does not have an enforceable DTT or TIEA in place). If the DTT provides for two rates, the lower rate applies mostly in situations when the interest is received by the government, the central bank, or a state-owned institution. Under domestic law, interest income from Czech governmental bonds is exempt. Furthermore, interest from bonds issued by Czech companies abroad (i.e. issued under foreign law) is also exempt from the WHT, provided that the bondholder is not a related party of the issuer.

The general WHT rate for royalties paid to non-residents is 15% (35% for royalties paid to residents of non-EU and non-EEA countries with which the Czech Republic does not have an enforceable DTT or TIEA in place). If the DTT provides for two rates, the lower rate applies mostly to cultural royalties.

In case that Switzerland (based on the Swiss law) does not levy any WHT on royalties paid to the Czech tax resident (not only Swiss tax residents), then the Czech Republic is allowed to reduce 10% WHT (as stated in Article 12 of the CZ-CHE DTT) to 5% WHT rate as a reciprocity provision with regard to 0% WHT in Switzerland.

There is no DTT in place with Taiwan. A special law was introduced by the Czech government (instead of a DTT) to implement the WHT rates with respect to Taiwan.

On 11 August 2023, Russia suspended application of Articles 5-22 and 24 of the Czech-Russian DTT. The Czech Republic took reciprocal measures as of 29 September 2023.

Apart from dividends, interest, and royalties, Czech tax residents or Czech PEs are obligated to withhold tax from Czech-source income of non-residents, among others, in the following cases:

Payments for services provided by a non-resident in the Czech Republic.

Provision of gifts and similar consideration-free transfers.

This treatment has to be applied unless an applicable DTT stipulates otherwise.

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