SolvedDT17002 | Double Taxation Relief Manual: Slovak Republic: 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 the Slovak Republic 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 gov.uk.
| Subject | Comments | Article |
|---|---|---|
| Portfolio dividends | 15% | 10 |
| Dividends on direct investments | 5% (Note 1) | 10 |
| Conditions for lower rate on dividends on direct investments | The beneficial owner must be a company which controls at least 25% of the voting power in the paying company | 10 |
| Property income dividends | 15% | 10 |
| Interest | 0% | 11 |
| Royalties | 0%/10% (Notes 2 and 3) | 12 |
| Government pensions | Taxable only in the Slovak Republic unless the individual is a resident and national of the UK | 19 |
| Other pensions | Taxable only in the UK | 18 |
| Arbitration | No | N/A |
Note 1: Until 31 December 2020, under the EU Parent Subsidiary Directive, dividends beneficially owned by a company resident in the UK that has held at least 10% of the capital of the Slovak Republic company paying the dividend for an uninterrupted period of at least 24 months are exempt from tax in the Slovak Republic.
Note 2: The 0% rate applies to royalties for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films or tapes for radio and television broadcasting). All other royalties are taxable in the Slovak Republic at a rate not exceeding 10%.
Note 3: Until 31 December 2020, interest and royalties paid by a Slovak Republic company to an associated UK company will be exempt under the terms of the EU Interest and Royalties directive where the conditions of the Directive are met.