| Withholding Tax Rates for Royalties |
| under
Thailand's DTAs |
| if the
recipient of royalties does not have a P.E. or fixed base in the source
country |
| Country |
Tax
Rate not exceeding |
Types
of Royalties |
| 1. Germany |
5 |
use
of or the right to use any copyright of literary, artistic or scientific work |
| |
15 |
other
royalties |
| |
|
Note
: also apply to the gains from the alienation of any right or property |
| |
|
giving
rise to such royalties if such right or property is alienated by a |
| |
|
resident
of a Contracting State for exclusive use in the other Contracting |
| |
|
State
and the payment of such right or property is borne by an enterprise |
| |
|
of
that other State or a permanent establishment situated therein |
| |
|
|
| 2. France |
5 |
alienation
or use of or the right to use any copyright of literary, artistic or |
| |
|
scientific
work |
| |
15 |
other
royalties |
| |
Exempt |
royalties
or other like payments payable to a Contracting State or a |
| |
|
State
owned company in respect of films or tapes |
| |
10 |
as long as the tax rate provided by the French law on the
royalties |
| |
|
received by a French resident as consideration for the
alienation of, |
| |
|
or the exclusive right to use any patent, process or
information |
| |
|
concerning industrial experience does not exceed 10 per
cent, |
| |
|
the tax charged in the Contracting State in which such
royalties arise |
| |
|
shall not exceed 10 per cent. |
| |
|
|
| 3. Singapore |
15 |
all
royalties |
| |
|
|
| 4. Netherlands |
5 |
use
of or the right to use any copyright of literary, artistic or scientific work |
| |
15 |
other
royalties |
| |
|
|
| 5. Italy |
5 |
use
of or the right to use any copyright of literary, artistic or scientific work |
| |
15 |
other
royalties |
| |
|
|
| 6. Belgium |
5 |
use
of or the right to use any copyright of literary, artistic or scientific work |
| |
15 |
other
royalties |
| |
|
|
| 7. Pakistan |
10 |
alienation
or use or the right to use any copyright of literary, artistic |
| |
|
or
scientific work |
| |
20 |
other
royalties (Note: For royalties
arising in Thailand, apply 15% in |
| |
|
accordance
with the Revenue Code) |
| |
Exempt |
royalties
or other like payments payable to a Contracting State or a |
| |
|
State
owned company in respect of films or tapes |
| |
|
|
| 8. United Kingdom |
5 |
use
of or the right to use any copyright of literary, artistic or scientific work |
| |
15 |
other
royalties |
| |
|
|
| 9. Malaysia |
15 |
all
royalties except any royalty or other amount paid in respect of |
| |
|
motion
picture films or of tapes for
radio or television broadcasting, or |
| |
|
of
the operation of a mine, oil
well, quarry or any other
place of |
| |
|
extraction
of natural resources or of timber or other forest produce |
| |
Exempt |
approved
industrial royalties derived from Malaysia by a resident of |
| |
in Malaysia |
Thailand |
| |
|
|
| 10. Philippines |
15 |
if
the royalties are paid |
| |
|
(1)
by an enterprise registered with the
Philippine Board of |
| |
|
Investments and engaged in
preferred areas of activities; or |
| |
|
(2)
by an enterprise under the promotion of the Board of Investment |
| |
|
of Thailand; or |
| |
|
(3)
in respect of cinematographic films or tapes for television or |
| |
|
broadcasting |
| |
25 |
other
royalties (Note: For royalties arising in Thailand, apply 15% in |
| |
|
accordance
with the Revenue Code) |
| |
|
|
| 11. Poland |
5 |
alienation,
use of or the right to use any copyright of literary, artistic or |
| |
|
scientific
work excluding cinematographic films or tapes for television |
| |
|
or
broadcasting |
| |
15 |
other
royalties |
| |
Exempt |
royalties
or other like payments payable to a Contracting State or a |
| |
|
State
owned company in respect of films or tapes |
| |
|
|
| 12. Canada |
5 |
copyright
royalties and other like payments in respect of the production |
| |
|
or
reproduction of any literary, dramatic, musical or artistic work (but
not |
| |
|
including
royalties in respect of motion picture films and works on film |
| |
|
or
videotape for use in connection with television) |
| |
|
(alienation,
the use of, or the right to use) |
| |
15 |
all
royalties |
| |
|
|
| 13. Finland |
15 |
all
royalties |
| |
|
|
| 14. India |
15 |
all
royalties |
| |
|
|
| 15. Austria |
15 |
all
royalties |
| |
|
|
| 16. China |
15 |
all
royalties |
| |
|
|
| 17. Sweden |
15 |
all
royalties |
| |
|
|
| 18. Hungary |
15 |
all
royalties |
| |
|
|
| 19. Australia |
15 |
all
royalties |
| |
|
|
| 20. Sri Lanka |
15 |
all
royalties |
| |
|
|
| 21. Japan |
15 |
all
royalties |
| |
|
|
| 22. Vietnam |
15 |
all
royalties |
| |
|
|
| 23. Czech Republic |
5 |
alienation
or use of or the right to use any copyright of literary, artistic or |
| |
|
scientific
work, excluding cinematograph films or films or tapes used for |
| |
|
radio
or television broadcasting |
| |
10 |
alienation
of any patent, trademark, design or model, plan, secret |
| |
|
formula
or process |
| |
15 |
other
royalties |
| |
|
|
| 24. Switzerland |
5 |
alienation
or use of, or the right to use any copyright, artistic or scientific |
| |
|
work,
excluding cinematograph films or films or tapes used for radio or |
| |
|
television
broadcasting |
| |
10 |
alienation
of any patent, trade mark, design or model, plan, secret |
| |
|
formula
or process |
| |
15 |
other
royalties (However, Thailand shall tax at the rate not exceeding 10 |
| |
|
percent
if Switzerland does not, according to its internal law, levy a tax |
| |
|
at
source on royalties paid to non-residents and for tax credit purposes, |
| |
|
allows
as a deductible expense 50 per cent of the gross amount of |
| |
|
royalties |
| |
|
|
| 25. Israel |
5 |
use
of or the right to use any copyright of literary, artistic or scientific work |
| |
|
excluding
cinematograph films or films or tapes used for radio or |
| |
|
television
broadcasting |
| |
15 |
other
royalties |
| |
|
|
| 26. South Africa |
15 |
all
royalties |
| |
|
|
| 27. Romania |
15 |
all
royalties |
| |
|
|
| 28. United States of
America |
5 |
use
of or the right to use any copyright of literary, artistic or scientific work |
| |
|
including
software, and motion pictures and works on film, tapes or |
| |
|
other
means of reproduction for use in connection with radio or |
| |
|
television
broadcasting |
| |
8 |
use
of or the right to use industrial, commercial or industrial equipment |
| |
15 |
other
royalties |
| |
|
|
| 29. Laos |
15 |
all
royalties |
| |
|
|
| 30. Mauritius |
5 |
use
of or the right to use any copyright of literary, artistic or scientific work |
| |
|
excluding
cinematograph films and films, tapes or discs used for radio |
| |
|
or
television broadcasting |
| |
15 |
other
royalties |
| |
|
|
| 31. Luxembourg |
15 |
all
royalties |
| |
|
|
| 32. Bangladesh |
15 |
all
royalties |
| |
|
|
| 33. Nepal |
15 |
all
royalties |
| |
|
|
| 34. Spain |
5 |
use
of, or the right to use, any
copyrights of literary, dramatic, musical |
| |
|
artistic
or scientific work, excluding cinematograph films or films or |
| |
|
tapes
used for radio or television broadcasting |
| |
8 |
financial
leasing for the use of, or the right to use, industrial, commercial |
| |
|
or
scientific equipment |
| |
15 |
other
royalties |
| |
|
|
| 35. New Zealand |
10 |
use
of or the right to use any copyright, any industrial, commercial or |
| |
|
scientific
equipment, any motion picure film or film or videotape or any |
| |
|
other
recording for use in connection with television, or tape or any other |
| |
|
recording
in connection with radio broadcasting; the reception of, or the |
| |
|
right
to receive, visual images or sounds or both & the use in connection |
| |
|
with
television or radio broadcasting, visual images or sounds, or both, |
| |
|
transmitted
by satellite or cable, optic fibre or similar technology |
| |
15 |
other
royalties |
| |
|
|
| 36. Denmark |
5 |
use or the right to use any copyright of literary, artistic
or scientific work |
| |
15 |
other
royalties |
| |
|
|
| 37. Uzbekistan |
15 |
all
royalties |
| |
|
|
| 38. Cyprus |
5 |
use
of or the right to use any copyright of literary, dramatic, musical, |
| |
|
artistic
or scientific work, including software, cinematograph films or |
| |
|
or
tapes used for radio or television broadcasting |
| |
10 |
use
of, or the right to use, industrial, commercial or scientific equipment |
| |
|
or
for information concerning industrial, commercial or scientific |
| |
|
experience |
| |
15 |
other
royalties |
| |
|
|
| 39. United Arab Emrates |
15 |
all
royalties |
| |
|
|
| 40. Bulgaria |
5 |
use
or the right to use any copyright of literary, artistic or scientific work |
| |
|
excluding
cinematography films and films, tapes or discs for radio or |
| |
|
television
broadcasting |
| |
15 |
other
royalties |
| |
|
|
| 41. Armenia |
15 |
all
royalties |
| |
|
|
| 42. Indonesia |
15 |
all
royalties |
| |
|
|
| 43. Norway |
5 |
use
or the right to use any copyright of literary, artistic or scientific work |
| |
10 |
use
or the right to use industrial, commercial or scientific equipment |
| |
15 |
other
royalties |
| |
|
|
| 44. Bahrain |
15 |
all
royalties |
| |
|
|
| 45. Oman |
15 |
all
royalties |
| |
|
|
| 46. Slovenia |
10 |
use
of or the right to use any copyright of literary, artistic or scientific work |
| |
|
including
motion pictures, live broadcasting, film, tape or other means |
| |
|
of
the use or reproduction in connection with radio and television |
| |
|
broadcasting,
and for the use of, or the right to use industrial, |
| |
|
commercial
or scientific equipment |
| |
15 |
other
royalties |
| |
|
|
| 47. Ukraine |
15 |
all
royalties |
| |
|
|
| 48. Turkey |
15 |
all
royalties |
| |
|
|
| 49. Hong Kong |
5 |
use
of, or the right to use, any copyright of literary, artistic or scientific |
| |
|
work |
| |
10 |
use
of, or the right to use, any patent, trademark, design or model, plan, |
| |
|
secret
formula or process |
| |
15 |
other
royalties |
| |
|
|
| 50. Seychelles |
15 |
all
royalties |
| |
|
|
| 51. Kuwait |
20 |
all
royalties (Note: For royalties arising in Thailand, apply 15% in |
| |
|
accordance
with the Revenue Code) |
| |
|
|
| 52. Korea |
5 |
use
of, or the right to use, any copyright of literary, artistic or scientific |
| |
|
work |
| |
10 |
use
of, or the right to use, any patent, trademark, design or model, plan, |
| |
|
secret
formula or process |
| |
15 |
other
royalties |
| |
|
|
| 53. Russian |
15 |
all royalties |
| |
|
|
| 54. Chile |
10 |
use of or the right to use any copyright of literary, artistic or |
| |
|
scientific work, or use of or the right to use industrial, commercial or |
| |
|
scientific equipment |
| |
15 |
other
royalties |
| |
|
|
