Price Waterhouse Romania: Flash Report No.11

A revised Double Tax Treaty between Belgium and Romania has recently been ratified by the Romanian Parliament and likely to come into place early next year.

The features of this treaty include the following withholding tax rates:

1. Royalty withholding tax - 5%
2. Interest withholding tax - 10%
3. Dividend withholding tax 5% if paid to a shareholder with more than 25% shareholding (15% otherwise)

The treaty also has the following provisions that are likely to be introduced in all future treaties:

1. The 183 days rule for individual taxation has been extended to 183 days in any twelve month period (not calendar year). This provision conforms to the relevant provision in Romanian domestic legislation.