The IBFD has received the English and Spanish texts of the Venezuela - Switzerland double taxation treaty of 20 December 1996. The treaty was concluded in the French, Spanish and English languages; in case of divergence, the English text prevails. The treaty generally follows the OECD Model Convention.
Under the treaty, the maximum withholding tax rates are:
- 10% on dividends, but dividends are exempt from withholding tax if the beneficial owner is a company (other than a partnership) which holds directly at least 25% of the company paying the dividends;
- 5% on interest, but the usual exemptions for interest paid to public bodies, etc. apply; and
- 5% on royalties.
A building site or a construction or installation project constitutes a permanent establishment only if it lasts for more than 12 months starting from the date on which the work actually begins.
