New DTT between Austria and the United Kingdom and Northern Ireland effective 1 January 2020

UniCredit Bank Austria AG
Summary: 
A new DTT between Austria and the United Kingdom and Northern Ireland to be effective as of 1 January 2020.
Thu, 02/01/2020

A new DTT between Austria and the United Kingdom and Northern Ireland to be effective as of 1 January 2020.

The maximum withholding tax rates stipulated in the new tax treaty between Austria and UK are as follows:

Dividends (Article 10)

  • 10%  of the gross amount of the dividend, except as provided in sub-paragraph a) ii) (see Article 10 (2))

  • 15% where the dividend is paid by a relevant investment vehicle (see definition Article 10 (6)

  • 0% if the beneficial owner of the dividend is:

                 a.  a company (other than a partnership) which is a resident of the other Contracting State and controls, directly or indirectly, at least 10 per cent of the voting power in the company paying the dividends (other than where the dividends are paid by a relevant investment vehicle); or

                 b.      a pension scheme

 Interest (Article 11)

  •  0%

The full wording of the DTT is available in English under the following link:

 https://www.ris.bka.gv.at/Dokumente/BgblAuth/BGBLA_2019_III_32/COO_2026_100_2_1618759.html


Impact on investors: The new DTT will apply in Austria for all income received from 1 January 2020 onwards, however tax reclaims will be possible on 1 January 2021 at the earliest.