DT6509 - DT: Egypt: double taxation agreement, Article 10: Dividends
- A dividend derived from a company which is a resident of the
United Kingdom by a resident of Egypt may be taxed in Egypt. Such
dividend may also be taxed in the United Kingdom and according to
the laws of the United Kingdom but where it is beneficially owned
by a resident of Egypt the tax so charged shall not exceed 20 per
cent of the gross amount of the dividend.
- A dividend derived from a company which is a resident of Egypt
by a resident of the United Kingdom may be taxed in the United
Kingdom. Such dividend may also be taxed in Egypt and according to
the laws of Egypt provided that:
- the dividend shall be allowed as a deduction from the amount of
the taxable profits of the company to the extent that it does not
exceed the amount of those profits before such deduction; and
- where such dividend is beneficially owned by an individual who
is a resident of the United Kingdom the general income tax imposed
on the dividend shall not exceed 20 per cent of the amount of that
dividend after deduction of Egyptian tax (other than the general
income tax).
- The term `dividend` as used in this Article means income from
shares jouissance shares or jouissance rights, founders' shares or
other rights, not being debt- claims, participating in profits, as
well as income from other corporate rights treated in the same
manner as income from shares by the taxation law of the State of
which the company making the distribution is a resident and also
includes any other item (other than interest relieved from tax
under the provisions of Article 11) which is treated as a
distribution under the taxation law of the Contracting State of
which the company making the payment is a resident.
- The provisions of paragraphs (1) and (2) of this Article shall
not apply if the beneficial owner of the dividend, being a resident
of a Contracting State, carries on business in the other
Contracting State of which the company paying the dividend is a
resident, through a permanent establishment situated therein, or
performs in that other State professional services from a fixed
base situated therein and the holding in respect of which the
dividend is paid is effectively connected with such permanent
establishment or fixed base. In such a case the provisions of
Article 7 or Article 14, as the case may be, shall apply.
- Where a company which is a resident of a Contracting State
derives profits or income from the other Contracting State, that
other State may not impose any tax on the dividends paid by the
company, except insofar as such dividends are paid to a resident of
that other State or insofar as the holding in respect of which the
dividends are paid is effectively connected with a permanent
establishment or a fixed base situated in that other State, nor
subject the undistributed profits of the company to a tax on
undistributed profits, even if the dividends paid or the
undistributed profits consist wholly or partly of profits or income
arising in that other State.
Provided that nothing in this paragraph shall affect the application in Egypt of Article 11 (paragraphs (1) and (2)) and Article 11 bis of Law No 14 of 1939 as they may be amended from time to time in minor respects without affecting the general principle thereof.
