SolvedDT16052 | Double Taxation Relief Manual: Romania: treaty summary
From HM Revenue & Customs · Double Taxation Relief Manual
The table summarises the provisions of the treaty as they relate to income beneficially owned by UK residents. The rate shown is the ‘treaty rate’ and does not reflect taxes chargeable under domestic law before relief is given under the provisions of the treaty. The ‘treaty rate’ is the maximum rate at which Ecuador is permitted to tax income in the relevant categories under the treaty. Rates chargeable under domestic law may be higher or lower.
In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. The text of the treaty itself should be consulted for the full details. The text of the treaty can be found on: Romania: tax treaties - GOV.UK
| Subject | Comments | Article |
|---|---|---|
| Portfolio dividends | 5% | 10 |
| Dividends on direct investments | 0% | 10 |
| Condition for lower rate on dividends on direct investments | The beneficial owner must be a company which controls directly or indirectly at least 25 per cent of the voting power in the company paying the dividends for an uniterrupted period of at least one year. | 10 |
| Property income dividends | 15% | 10 |
| Interest | 3% | 11 |
| Interest exemptions | 0% rate for the following: Interest related to credit for the purchase of equipment, merchandise or services. Paid to recognised pension fund. Paid to an institution or agency of the other State. Intragroup payment of interest with a 25% holding. | 11 |
| Royalties | 3% | 12 |
| Royalties exemptions | 0% rate for intragroup payments of royalties with a 25% holding | 13 |
| Government pensions | Taxable only in Romania unless the individual is a UK resident and national | 18 |
| Other pensions | Taxable only in Romania unless the individual is a UK resident and national. | 17 |
| Arbitration | No | N/A |