Categories:Tax,United States

Treaty developments further US commitment to fostering cross-border investment

Since the start of 2013, there have been three major developments on the US tax treaty front: a new protocol with Spain signed on 14 January, a new protocol with Japan signed on 24 January and a revised treaty with Poland signed on 13 February. While these agreements are not yet in force, they tell us a great deal about the aims of this US administration around cross-border investment.

Under the new Spain protocol, dividends paid to parent companies meeting certain requirements are exempt from withholding tax; otherwise, the rate is 5 percent if the beneficial owner directly owns at least 10 percent of the subsidiary’s voting stock or 15 percent in all other cases.

The new Japan protocol and revised Poland treaty both maintain a 5-percent dividend withholding tax rate for parent companies that own at least 10 percent of the subsidiary’s voting stock. For companies that own less than 10 percent of such stock, the rate is favorably reduced from 15 to 10 percent. The new Japan protocol further broadens a full exemption from withholding tax for parent companies that (i) own “at least” 50 percent of the subsidiary’s voting stock and (ii) hold such stock for six months. The revised Poland treaty exempts dividends paid to pension funds…

If you are registered and logged in to the site, click on the link below to read the rest of the DLA Piper briefing. If not, please register or sign in with your details below.

Sign in or Register to continue reading this article

Sign in

Register

It's quick, easy and free!

It takes just 5 minutes to register. Answer a few simple questions and once completed you’ll have instant access.

Register now

Why register to The Lawyer

 

Industry insight

In-depth, expert analysis into the stories behind the headlines from our leading team of journalists.

 

Market intelligence

Identify the major players and business opportunities within a particular region through our series of free, special reports.

 

Email newsletters

Receive your pick of The Lawyer's daily and weekly email newsletters, tailored by practice area, region and job function.

More relevant to you

To continue providing the best analysis, insight and news across the legal market we are collecting some information about who you are, what you do and where you work to improve The Lawyer and make it more relevant to you.

Briefings from DLA Piper

View more briefings from DLA Piper

Analysis from The Lawyer

View more analysis from The Lawyer

Overview

3 Noble Street
London
EC2V 7EE
UK
http://www.dlapiper.com

Turnover (£m): 1,566.29
No. of lawyers: 3,961 (UK 200)
Jurisdiction: global
No. of offices: more than 75
No. of qualified lawyers: 625 (International 50)

Jobs