Debt securities – Double Taxation Treaties concluded by the Slovak Republic and currently in force
Note: Clearstream Banking provides these rates for information purposes only and does not guarantee that this information is correct, complete and accurate. Clearstream Banking does not assume liability for any damages, direct or indirect, that may arise from the reliance on or the use of this information. The rate as prescribed in the Double Taxation Treaties (“DTT(s)”) assumes that the beneficial owner does not hold a substantial percentage of the share capital of the company paying the dividend. Different rates may apply for substantial holdings. Please refer to the actual DTT or your tax advisor for further information.
The standard rate of withholding tax on dividends is, as of 1 January 2022, 25% before any refund (26.5% before 1 January 2022, 28% before 1 January 2021 and 30% before 1 January 2020).
Country a | Rate prescribed by the DTT – Interest (%) | Tax refund |
Armenia (WL) | 10 | 9 |
Australia (WL) | 10 | 9 |
Austria (WL) | 0 | 19 |
Belarus (WL) | 10 | 9 |
Belgium (WL) | 10 | 9 |
Bosnia and Herzegovina (WL) | 0 | 19 |
Brazil (WL) | 15 | 4 |
Bulgaria (WL) | 10 | 9 |
Canada (WL) | 10 | 9 |
| China (People's Rep.) | 10 | 25 |
Chinese Taipei (WL) | 10 | 9 |
Croatia (WL) | 10 | 9 |
Cyprus (WL) | 10 | 9 |
Czech Republic (WL) | 0 | 19 |
Denmark (WL) | 0 | 19 |
Estonia (WL) | 10 | 9 |
Ethiopia (WL) | 5 | 14 |
Finland (WL) | 0 | 19 |
France (WL) | 0 | 19 |
Georgia (WL) | 5 | 14 |
Germany (WL) | 0 | 19 |
Greece (WL) | 10 | 9 |
Hungary (WL) | 0 | 19 |
Iceland (WL) | 0 | 19 |
India (WL) | 15 | 4 |
Indonesia (WL) | 10 | 9 |
Ireland (WL) | 5 | 14 |
Israel (WL) | 0 | 19 |
Italy (WL) | 0 | 19 |
Japan (WL) | 10 | 9 |
| Kazakhstan (WL) | 10 | 9 |
Korea (Rep.) (WL) | 10 | 9 |
Kuwait (WL) | 10 | 9 |
Latvia (WL) | 10 | 9 |
Libya (WL) | 10 | 9 |
Lithuania (WL) | 10 | 9 |
Luxembourg (WL) | 0 | 19 |
Malaysia (WL) | 10 | 9 |
Malta (WL) | 0 | 19 |
Mexico (WL) | 10 | 9 |
Moldova (WL) | 10 | 9 |
Montenegro (WL) | 10 | 9 |
Netherlands (WL) | 0 | 19 |
Nigeria (WL) | 15 | 4 |
North Macedonia (WL) | 10 | 9 |
Norway (WL) | 0 | 19 |
Oman (WL) | 10 | 9 |
Poland (WL) | 5 | 14 |
Portugal (WL) | 10 | 9 |
Romania (WL) | 10 | 9 |
Russia | 0 | 35 |
Serbia (WL) | 10 | 9 |
Singapore (WL) | 0 | 19 |
Slovenia (WL) | 10 | 9 |
South Africa (WL) | 0 | 19 |
Spain | 0 | 35 |
Sri Lanka (WL) | 10 | 9 |
Sweden (WL) | 0 | 19 |
Switzerland (WL) | 0/5 c | 19/12 |
Syria (WL) | 10 | 9 |
Tunisia (WL) | 12 | 7 |
Turkey (WL) | 10 | 9 |
Turkmenistan (WL) | 10 | 9 |
Ukraine (WL) | 10 | 9 |
United Arab Emirates (WL) | 10 | 9 |
United Kingdom (WL) | 0 | 9 |
United States of America | 0 | 35 |
| Uzbekistan (WL) | 10 | 9 |
Vietnam (WL) | 10 | 9 |
a. The reference to “(WL)” means that the country is part of the “white-list countries” identified for tax purposes by the Slovak authorities.
b. The % reflected in this column is the result of the default tax rate applied to interest derived from Slovak corporate bonds (including mortgage/bank bonds) between 1 January 2023 and 17 April 2023 (included), that is, 19% for white-list countries, 35% for other countries, on the one hand, and the relevant DTT rate mentioned in the middle column of this table, on the other hand.
c. Both rates are given as neither of them seems to reflect the main rule – each case is considered as “special” and subject to either rate, depending on the relevant local tax rule.