Dividend withholding tax (‘DWT’) is withheld at source by the entity paying out the dividend to its shareholder at a flat tax rate of 15%. Under certain conditions no DWT has to be withheld, for example due to the so called mother/daughter directive which is mostly applicable in case of a 5% (or more) shareholder located in the EU or in case the applicable tax treaty to avoid double taxation lowers the DWT to 0%.
As of the year 2018 – even when the applicable tax treaty does not lower the DWT to 0% – there is no DWT in case a shareholder has 5% or more of the shares and all anti abuse measures are met by this shareholder.
