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Withholding tax rates on dividends: symmetries versus asymmetries or single- versus multi-rated double tax treaties

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  • Kunka Petkova

    (Vienna University of Economics and Business)

Abstract

Out of all double tax treaties (DTTs) in force in 2012, around 41% are symmetric (single-rated) and 59% are asymmetric (multi-rated), i.e., they prescribe different dividend withholding tax rates depending on the foreign investor’s ownership fraction. The paper investigates the reasons for this phenomenon, namely why some countries in their DTTs prefer homogenous withholding tax rates over separate rates for participation and portfolio dividends. In a theoretical model, I demonstrate why home countries may have an interest in a high withholding tax rate in the host country, even though they do not receive the revenue from this tax. Further, I find confirming evidence that a reason for having multi-rated withholding taxes on dividends is an existing spatial dependence on the rates of the countries’ peers that may be a driving factor for setting multi-rated taxes. Finally, I confirm that the spread itself (i.e., the difference between the portfolio and participation dividends negotiated in the tax treaty) is also affected by the peer countries.

Suggested Citation

  • Kunka Petkova, 2021. "Withholding tax rates on dividends: symmetries versus asymmetries or single- versus multi-rated double tax treaties," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 28(4), pages 890-940, August.
    • Handle: RePEc:kap:itaxpf:v:28:y:2021:i:4:d:10.1007_s10797-020-09637-y
    DOI: 10.1007/s10797-020-09637-y
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    References listed on IDEAS

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    1. Chisik, Richard & Davies, Ronald B., 2004. "Asymmetric FDI and tax-treaty bargaining: theory and evidence," Journal of Public Economics, Elsevier, vol. 88(6), pages 1119-1148, June.
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    6. Kunka Petkova & Andrzej Stasio & Martin Zagler, 2020. "On the relevance of double tax treaties," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 27(3), pages 575-605, June.
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    Cited by:

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    More about this item

    Keywords

    Double tax treaties; Withholding tax rates; Dividends; Portfolio dividends; Participation dividends;
    All these keywords.

    JEL classification:

    • F23 - International Economics - - International Factor Movements and International Business - - - Multinational Firms; International Business
    • F53 - International Economics - - International Relations, National Security, and International Political Economy - - - International Agreements and Observance; International Organizations
    • H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies
    • H26 - Public Economics - - Taxation, Subsidies, and Revenue - - - Tax Evasion and Avoidance
    • H73 - Public Economics - - State and Local Government; Intergovernmental Relations - - - Interjurisdictional Differentials and Their Effects
    • H87 - Public Economics - - Miscellaneous Issues - - - International Fiscal Issues; International Public Goods
    • K34 - Law and Economics - - Other Substantive Areas of Law - - - Tax Law

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