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  • Residence and basis for taxation

    In Argentina coexist three levels of taxation which are Federal, Provincial (state) and Municipal level.

    An entity is deemed as resident for tax purposes when it is incorporated in Argentina under the laws of Argentina. An Argentine individual is considered a tax resident unless he or she loses his tax residence status by choice, obtains legal residence in other country, or by fact, when the individual is outside the country for at least a twelve months period, with certain exemptions.

    Domestic 

    Local entities and resident individuals are subject to income tax on domestic and foreign source income.

    Foreign 

    Non resident entities or individuals are taxed on income of Argentine source. The tax applicable is the income tax that comprises corporate earnings and capital gains. In general, a local resident paying to a foreign entity or individual is obliged to withhold income tax. The withholding rate varies in connection with the type of the payment.

    Permanent establishments are taxed as local entities on income attributable to the permanent establishment.

    Income tax on indirect transfer

    Income tax on an indirect transfer may apply if a non resident entity is transferred provided that at least 30 percent of value of the entity is represented by assets located in Argentina and provided that the transferor owns at least 10 percent of the capital of such entity.

  • Taxable income

    Domestic

    In general the taxable income in the income tax for resident entities and resident individuals is equal to gross earnings minus deductions. In general, all expenses incurred to obtain, maintain and preserve taxable income are deductible unless expressly forbidden.

    Foreign 

    Non resident entities and individuals are taxed in the income tax on the incomes of Argentine source. The local resident paying to a foreign entity or individual is obliged to withhold the income tax at a 35 percent tax rate applied on a presumption of taxable income that varies in connection with the concept by which the payment is made. The presumption of taxable income can be from 35 percent up to 90 percent of the amounts paid.

    For incomes connected to the transfer of shares, bonds or titles, or incomes connected with the rental of real estate or the transfer of assets located in Argentina owned by a non resident, the non resident individual or entity is entitled to choose to apply the presumption of income or to present evidence of all the expenses incurred and deduct those expenses from the gross amount to be paid.

  • Tax rates

    Domestic

    Local entities are subject to an income tax rate of 30% for fiscal year 2019 and 25% as of fiscal year 2020.

    In general, local individuals are taxed at a progressive tax rate that goes from 5% to 35%, except for earnings with a fixed tax rate. Those are the following:

    • For local individuals the transfer of sovereign bonds, or any title is taxed at a 5% income tax rate if the title is issued in Argentine pesos, or 15% income tax rate if a share of a corporation is transferred, or if the title or sovereign bond is issued in Argentine pesos with adjustment clause or in foreign currency
    • The transfer of real estate by a local individual is taxed at a 15% of income tax rate
    • Interests of financial investments such as bank deposits, sovereign bonds, negotiable obligations, financial trusts and similar, issued in Argentine pesos without adjustment clause, are taxed at an income tax rate of 5%. The applicable tax rate is 15% when issued in Argentine pesos with adjustment clause or when issued in foreign currency
    • Dividends paid to a local individual are taxed at a 7% tax rate for fiscal year 2019 and 13% as of fiscal year 2020

    Foreign

    In general non resident entities and individuals are taxed at an income tax rate of 35% applied on the presumption of taxable income with effective tax rates of 12.5% up to 31.5% (see Taxable Incomes). Some concepts are not taxed at the general 35% tax rate and are taxed to an specific tax rate.

    • Transfer of sovereign bonds or any title (public or private) is taxed at a 5% income tax rate if the title is issued in Argentine pesos, or 15% income tax rate if the title is issued in Argentine pesos with adjustment clause, or in foreign currency. The transfer of shares of a local corporation is taxed at a 15% income tax rate. This assumes that the foreign beneficiary is in a jurisdiction considered as cooperative for tax purposes
    • Interests of financial investments such as bank deposits, sovereign bonds, negotiable obligations, financial trusts and similar, issued in Argentine pesos without adjustment clause are taxed at an income tax rate of 5%. The applicable tax rate is 15% when issued in Argentine pesos with adjustment clause or when issued in foreign currency. This provided that the foreign beneficiary is in a jurisdiction considered as cooperative for tax purposes
    • Dividends paid to a non resident individual or entity are taxed at a 7% tax rate for fiscal year 2019 and 13% as of fiscal year 2020

    The applicable tax rates can be lower if a double taxation treaty is applicable.

  • Tax compliance

    Local entities and individuals are obliged to fill tax returns at federal, state and municipal level depending on their activities. Tax returns mas be filled on monthly or yearly bases depending on the tax.

    Information regimes are applicable to certain activities.

    Advance payment regimes are applicable for some taxes.

  • Alternative minimum tax

    Not applicable for this jurisdiction.

  • Tax holidays, rulings and incentives

    Tax holidays

    Not applicable for this jurisdiction.

    Tax rulings 

    In some cases, taxpayers are entitled to present to the tax authorities a request for a ruling on a specific case. The ruling is binding for the consultant. 

    Tax incentives

    There are tax incentives at the federal, state and municipal level which target specific activities such as renewables and software services and development.

  • Consolidation

    Not applicable for this jurisdiction.

  • Participation exemption

    Argentina tax legislation does not provide for a participation exemption.

    Dividends paid by a local entity to another local entity are exempt from income tax. Dividends are only taxed when distributed to a local individual or to a foreign entity or individual.

  • Capital gain

    Capital gains are taxed by the income tax.

    Domestic and foreign, see Taxable income and Tax rates.

    Income tax or indirect transfer

    Income tax on indirect transfer may apply if a non resident entity is transferred provided that at least 30% of value of the entity is represented by assets located in Argentina and provided that the transferor owns at least 10% of the capital of such entity. When the transfer is carried on intragroup the income tax on indirect transfer is not applicable.

  • Distributions

    Distributions are taxed as dividends. Regardless of the tax residence of the recipient, dividends are taxed at a 7% tax rate for fiscal year 2019 and 13% as of fiscal year 2020.

    Domestic and foreign, see Taxable income and Tax rates.

  • Loss utilization

    Losses can be carried forward and can be offset with future profits for a five-year period.

    Losses considered to be of Argentine source can be offset only with profits considered to be of Argentine source. Losses considered to be of foreign source can only be offset of foreign source profits.

  • Tax-free reorganizations

    In Argentina it is possible to carry on an intragroup reorganization with no tax effects. Mergers, spinoffs or partial spinoffs are exempted from income tax, VAT and turnover tax if certain requirements are met.

    Income tax on indirect transfers can also be carried on with no tax costs if it is an intragroup transfer.

  • Anti-deferral rules

    According to CFC rules, the profits of a foreign entity directly or indirectly owned by a local entity or individual should be declared and taxed in the fiscal year of accrual in the following cases.

    • Trusts: When the trust is revocable, when the settlor is also the beneficiary, or when the resident individual or entity has full control of the trust
    • When the foreign entity is not considered a tax resident of the jurisdiction where it is incorporated
    • When:
      • The local individual or entity directly or indirectly owns at least 50% of the capital of the foreign entity
      • The foreign entity does not have sufficient structure to carry on its business or when at least 50% of the profits of the foreign entity are passive income
      • The taxes paid by the foreign entity in the country where it is incorporated are less than the 25% of the income tax that would be payable in Argentina (this requirement is deemed as occurred if the entity is incorporated in a non-cooperative jurisdiction)
  • Foreign tax credits

    Subject to conditions and limitations, foreign tax credits are available for foreign income taxes paid.

  • Special rules applicable to real property

    Domestic and foreign

    When a local entity or a non resident individual or entity sells or transfers real estate property located in Argentina, income tax is triggered.

    For resident individuals, if the real estate property that is being transferred has been acquired by the seller before January 1, 2018, no income tax is applicable, and the local individual must pay a special tax on transfer of real estate property. 

    There is the possibility of a tax deferral on the income tax applicable to the sale of a real estate property using a sale and replacement mechanism.

  • Transfer pricing

    Argentine transfer pricing rules apply to transactions between an Argentine party and a foreign related entity or any entity domiciled in a tax haven jurisdiction, a jurisdiction considered as non-cooperative, or that is subject to a privileged tax regime.

    Argentine transfer pricing rules follow arm's-length rule and follow the OECD guidelines with some divergences.

  • Withholding tax

    (see Taxable income and Tax rates.)

    Domestic

    Payments made by banks and financial institutions made to local entities or individuals in the case of interests on bank deposits or financial investments are subject to income tax withholding.

    Dividends paid by a local entity to a local individual are subject to income tax withholding. The tax rate applicable is 15%.

    Foreign

    Non resident entities or individuals are taxed on their income considered to be of Argentine source.

    The local payer is obliged to withhold the income tax at the time of the payment. Tax rates and presumptions of taxable income vary in connection with the type of payment made.

    Tax treaties may reduce or eliminate withholding of income tax.

  • Capital duty, stamp duty and transfer tax

    Capital gains are taxed by the income tax (see Taxable income and Tax rates.).

    Stamp duty or Stamp Tax is a provincial tax triggered by the entering of written agreements signed by both parties. The tax rate applicable varies in connection with the province and in connection with the agreement. Tax rates are of 0.2% up to 5% of the total amount of the agreement.

    There are legal mechanisms to avoid the payment of Stamp Tax by entering into an agreement as an offering letter.

    Transfers of shares, assets and real estate property are taxed under the income tax (see Taxable income and Tax rates.).

  • Employment taxes

    Employers must withhold income tax and social security contributions. Employers also must pay their share of social security contributions. These taxes are deductible by an employer for Argentine income tax purposes.

  • Other tax considerations

    Provincial taxes - Turnover tax

    Turnover tax or gross income tax is a tax collected by the provinces. The taxable event is the performance of commercial or industrial activity in the territory of the provinces. Tax rates can be 0.5% up to 6% in connection with the activity applied on the gross income. Some activities are charged with higher tax rates, such as online gambling which is taxed at a 15% tax rate in the Province of Buenos Aires.

    Every province has its own turnover tax. However, the turnover tax collected by each province are similar, although different tax treatments may result applicable for certain activities.

    Tax benefits

    For some activities there are special tax benefits at the federal level and provincial level.

    There are tax benefits for an investment in renewable energy, software production and services, investments in capital assets, biodiesel fuel and mining.

    The benefits may include partial or full exemptions, accelerated depreciation and drawback.

    VAT on the import of digital services

    Federal Government collects VAT on the importation of digital services. The taxpayer is the local resident unless the service provider has a fixed place in the Argentina. The tax rate is 21%.

    Double taxation treaties

    Argentina has signed tax treaties with Germany, Australia, Belgium, Bolivia, Brazil, Canada, Chile, Denmark, United Arab Emirates, Spain, Finland, France, Italy, Mexico, Norway, Netherlands, United Kingdom, Russia, Sweden and Switzerland (all in force), and Turkey, China, and Qatar (signed but not yet in force).

  • Key contacts
    Augusto Nicolás Mancinelli
    Augusto Nicolás Mancinelli
    Of Counsel DLA Piper (Argentina) [email protected] T +5411 41145500 View bio
    Raúl Sanguinetti
    Raúl Sanguinetti
    Tax Partner Baker Tilly Argentina [email protected] T +54 (11) 5352 2400 View bio

Participation exemption

Argentina

Argentina tax legislation does not provide for a participation exemption.

Dividends paid by a local entity to another local entity are exempt from income tax. Dividends are only taxed when distributed to a local individual or to a foreign entity or individual.

Australia

A Capital Gain Tax (CGT) exemption is available for the sale of an active foreign business by an Australian resident company.

Dividends received by resident corporate tax entities (eg, companies and corporate limited partnerships) that have a 10% or more equity interest in a foreign subsidiary are generally exempt from further Australian income tax.

However, these need to be addressed on a case by case basis.

Austria

Austrian dividends distributed to a resident company are exempt from corporate income tax under the national participation exemption rules (Beteiligungsertragsbefreiung). Foreign dividends distributed to a resident company are also exempt from corporate income tax. However, there are special provisions that differ between companies that are resident in an EU member state or in a state with which Austria signed an extensive tax administrative assistance agreement.

Belgium

Dividend income received by a Belgian company is subject to corporate tax at the standard rate. The Belgian participation exemption regime, however, allows for a deduction of 100% of the received dividend amount if certain conditions are met.

Brazil

Brazilian legislation does not provide for participation exemption. As a general rule, dividends received from other domestic legal entities are exempt. Note, however, that the Brazilian Government is studying possible changes to the rules regarding the payment exemption.

Canada

There is no general participation exemption for dividends or capital gains recognized on the stock of foreign subsidiaries. If certain ownership and source requirements are satisfied, a deduction may apply with respect to dividends received from certain domestic and foreign corporations.

China

Dividends received by a resident enterprise from another resident enterprise are exempt from enterprise income tax, except for dividends paid by a publicly listed enterprise to a shareholder that has continuously held the shares for less than 12 months.

Colombia

Law 1943, 2019, introduced the Colombian Holding Companies (CHC) regime for resident corporations. This regime establishes that:

  • Dividends received by a CHC from a foreign corporation are exempt from corporate income tax in Colombia. The same treatment applies when a CHC distributes dividends to a non-Colombian tax resident
  • Capital gains obtained by CHC from the sale of shares or interest in foreign entities are exempted from corporate income tax. The same treatment applies on the sale of shares in the CHC by a non-Colombian tax resident

Finland

Participation exemption regarding dividends covers dividends from unlisted companies in Finland, from foreign companies covered by EU parent subsidiary directive and from foreign companies pursuant to applicable tax treaty. Dividends received from a listed company are tax exempt only in case holding is at least 10%.

Participation exemption covers also capital gains of sale of shares in a company, but under strict criteria as follows. Shareholding at least 10% in target company, holding period at least one year, the sold shares are part of fixed assets, the target company is located in EU or tax treaty country and the main purpose of the target company is not to hold real estates. The participation exemption is not applicable to capital gain received by private equity companies.

France

A participation exemption regime is applicable to long-term capital gain (88% exempt) and dividends (as a rule 95% exempt), subject to a minimum shareholding of 5% of the share capital and a minimum holding period of 2 years. A specific participation-exemption regime applies to dividends distributed within a tax consolidated group (99% exempt) as well as, under conditions, to distributions made by foreign companies based in the EU, Iceland, Norway or Liechtenstein. Capital gain on the disposal of shares of real estate companies are excluded from the participation exemption regime.

Germany

Dividends and capital gain from the sale of shares in a domestic or foreign corporation received by a corporate shareholder are generally tax-free for corporate income tax purposes for shareholdings of at least 10 % and for trade tax purposes for shareholdings of at least 15%. An amount equal to 5% of the dividends or capital gain is treated as a non-deductible business expense and added to taxable income. In turn, the actual business expenses are fully deductible.

Hong Kong

Dividends received by a Hong Kong company are not subject to tax nor are dividends paid by a Hong Kong company to its shareholders, whether or not in Hong Kong.

India

There is no participation exemption for dividends received from, or capital gain recognized on the stock of, foreign subsidiaries.

Ireland

An exemption from corporate tax on chargeable gains applies to Irish resident companies on disposals of shareholdings in subsidiary companies, subject to the following conditions:

  • The subsidiary must be resident in the EU or in a country which has signed a double-taxation treaty with Ireland
  • The disposing company must hold 5% of the ordinary share capital of the subsidiary for a minimum of 12 continuous months. The disposing company must also be entitled to 5% of the subsidiary’s distributable profits and 5% of the subsidiary’s assets on a winding-up for this 12 month period and
  • The subsidiary must be a trading company or the disposing company, the subsidiary and all of the disposing company’s 5% subsidiaries must form a trading group

Ireland does not have a participation exemption for dividends. The tax treatment of dividends is discussed below.

Israel

Israeli corporations, which are entitled to the participation exemption regime, are entitled to a tax exemption on:

  • Dividends received from a "qualified foreign subsidiary"
  • Capital gains derived from the sale of shares of such subsidiary and
  • Financial income derived from investments on TASE
  • Interest and linkage difference derived from a financial institution

Dividends paid from a holding company to nonresidents will be entitled to a reduced withholding tax rate of 5%. In practice, this regime is rarely in use.

Italy

Dividends received from domestic and foreign corporations are 95% excluded from taxable basis, unless they are distributed by affiliates with a privileged tax treatment. The participation exemption on capital gain from the sale of participations applies when certain requirements are met, allowing an exemption of 95% of the capital gain.

Japan

Under Japanese tax law, there is no participation exemption for dividends received from, or capital gain recognized on the stock of, foreign subsidiaries. However, there is an exemption for dividends received from foreign subsidiaries (the so-called 95% foreign dividend exemption rule). Under this rule, if a Japanese shareholder has held 25% or more of the interest of a foreign company (the percentage could be lowered if a relevant tax treaty is applicable) for at least six months prior to the dividend determination date, 95% of dividends received from such foreign company, excluding the portion deductible in the foreign company's residing country, may be exempt from taxable income.

Luxembourg

Dividends and gains derived by a Luxembourg entity from a qualifying participation (broadly any entity subject to a corporate income tax rate of at least 8.5% applied on a tax base determined by the application of rules similar to those existing in Luxembourg) may be tax exempt if certain conditions in terms of shareholdings are met.

Mexico

There is no participation exemption for dividends received from, or capital gain recognized on, the stock of foreign subsidiaries.

Mexican companies that own shares of another Mexican entity may receive dividend distributions that should not be subject to further taxes, to the extent the dividends come from the net tax profit account (CUFIN).

Netherlands

Dividends from qualifying subsidiaries and capital gains from the sale of shares in a domestic or foreign subsidiary received by a Dutch corporate shareholder are exempted from tax, unless such payments are, directly or indirectly, deductible for corporate income tax purposes in the country of the subsidiary, irrespective of whether the deduction is actually claimed.

The participation exemption applies when at least 5% of the shares in the subsidiary are being held by the Dutch parent company and the subsidiary is not considered a low taxed passive portfolio investment company.

Norway

Dividends

Dividends received by a company tax resident in Norway, from another Norwegian company resident in Norway (or similar company resident in the European Economic Area (EEA)) are 97% exempt of tax. The remaining 3% are taxed with the ordinary corporate income tax rate of 22%. For dividends received from a company resident in in a low-tax jurisdiction with the FFA, the 97% exemption applies only if real business activities are conducted in that jurisdiction.

Dividends from group companies within the EEA are 100% exempt if more than 90% ownership.

Dividends received from a foreign company outside the EEA are 97% exempt if both of the criteria below are met:

  • The Norwegian company has held at least 10% of the shares and votes for at least two years
  • The foreign country is not a low-tax country

Capital gains

Capital gains derived by a Norwegian company on the realization of shares in another Norwegian (or EEA-resident) company are exempt from taxation. For capital gains derived by a Norwegian company on the realization of shares in an EEA-company resident in a low-tax jurisdiction, the exemption applies only if real business activities are conducted in that jurisdiction.

Capital gains derived by a Norwegian company on the realization of shares in a company resident outside of EEA are exempt from taxation if both of the criteria below are met:

  • The Norwegian company has held at least 10% of the shares and votes for at least two years
  • The foreign company is not resident in a low-tax jurisdiction

Poland

There is a participation exemption for dividends based on EU Parent-Subsidiary Directive. The exemption applies to dividends paid by the Polish company to EU company provided that this company holds at least 10% shares of the Polish company for a continuous period of at least 2 years. The exemption is not available if the dividend distribution aims tax avoidance.

Portugal

Dividends and capital gains arising from the disposal of participations in other companies are exempt from corporate tax provided the following requirements are cumulatively met:

  • The Portuguese Company, directly or indirectly, holds a minimum 10% of the capital or voting rights of its subsidiary
  • Such participation is held (or maintained) for a minimum period of 1 year
  • The Portuguese Company is not taxed under the tax transparency rules
  • The participated company is subject and not exempted from CIT or, if EU resident, from a tax mentioned under article 2 of Directive 2011/96/UE or, if resident outside the EU, from a tax similar to the CIT and the rate applicable under such CIT is not below 60% of the Portuguese CIT, but note this condition may be waived under certain circumstances (article 66(6) CIT Code)
  • The participated company is not resident in a black-listed jurisdiction

The capital gains exemption does not apply if the participated company has real estate in Portugal valuing more than 50% of its assets, unless such real estate is used in connection with an agricultural, industrial or commercial activity.

Romania

Participation exemptions apply where a minimum holding criteria of 10% for at least 1 year is met, for:

  • dividends received from an EU company or a company situated in a third country having concluded a tax treaty with Romania
  • capital gains derived from the sale of the participation titles in a Romanian company or a company resident of a tax treaty jurisdiction and
  • the liquidation of a Romanian company or a company resident of a tax treaty jurisdiction

Dividends received from a Romanian legal entity are non-taxable with no minimum holding requirements.

Russia

Dividends received by Russian organisations are taxed with corporate profits tax at a rate of 0%, under the following criteria:

  • The Russian legal entity receiving the dividend owns at least 50% of the capital of the paying entity (or owns depository receipts entitling it to receive at least 50% of the total amount of dividends paid) and has a right for at least 50% of the dividends declared
  • The participatory interest (shareholding) or depository receipts have been owned for at least 365 consecutive calendar days on the day the dividends are declared

Dividends received from foreign entities located in the offshore zones (the list of territories treated as the "offshore zones" for this purpose is established by the Ministry of Finance of the Russia) are not eligible to this exemption.

Singapore

Not applicable for this jurisdiction.

South Africa

In certain instances SA corporates can rely on participation exemptions for dividends received from or capital gains realised on the shares in foreign corporates.

South Korea

Not applicable for this jurisdiction.

Spain

Spanish resident corporations are entitled to the application of the participation exemption on dividends and capital gain received from foreign or domestic subsidiaries provided the following conditions are met:

  • Direct or indirect participation of at least 5% or €20 million acquisition value
  • The participation shall be held during the previous fiscal year, and
  • In the case of foreign subsidiaries, they shall be subject to corporate income tax in its country of residence similar to the Spanish Corporate Income Tax

This requirement will be satisfied when the foreign entity is subject to a Corporate Income Tax rate of at least 10% or the country of residence has signed a Double Tax Treaty with Spain which includes an information exchange clause.

Sweden

Dividends and capital gain on business-related shares are tax exempt in Sweden.

Dividends and capital gain on unlisted shares in a Swedish company are normally considered business-related unless the shares are classified as current assets or inventory. Generally, the shares should be classified as capital assets. If the shares are listed, the shares must represent 10% or more of the voting rights in the company and the shares must have been business-related for a period of at least one year.

If the shares are held in a foreign company, the same requirements apply. However, the foreign company must also be regarded as the foreign equivalent of a Swedish limited liability company.

Switzerland

Participation exemption is a proportional reduction from corporate income tax equal to the net participation income divided by taxable income. Net participation income is defined as the gross participation income from qualifying dividends or qualifying capital gains less related administration and financing costs and any depreciation of the participation that is linked to the dividend distribution or capital gain. In general, participation exemption results in a full exemption of participation income.

Qualifying dividends are dividends from investments representing at least 10% of the share capital or 10% of profits and reserves of another company or having a market value of at least CHF 1 million. There is no requirement that the dividend-distributing subsidiary is liable to income tax in its jurisdiction.

Qualifying capital gains are generally entitled to participation exemption if the following conditions are cumulatively met:

  • the investment sold was owned by the company for a period of at least 1 year and
  • it constitutes at least 10% of the share capital or 10% of profits and reserves of the underlying subsidiary.

Note that capital gains are only entitled to participation exemption provided the sales price exceeds the original investment costs. Hence previous depreciations on investments might be taxable.

Taiwan

Not applicable for this jurisdiction.

Turkey

A participation exemption is provided to dividends derived by resident companies from other Turkish companies. Dividends derived from non-residents may also benefit from participation exemption. Such dividends are exempt from tax provided that:

  • at least 10% of the non-resident company's paid-in capital is owned by the resident company for a period of at least 1 year from the receiving date of the dividend without any interruptions
  • the non-resident company is incorporated as a joint stock company or a limited liability company
  • the non-resident company is subject to a corporate tax with at least a 15% rate (20% in cases principal activity of the taxpayer is providing financing, including financial leasing, insurance or investment in marketable securities)
  • the dividends are remitted to Turkey by the date the filing of the annual corporate tax return is due

Ukraine

Domestic dividends received from payers of Ukrainian corporate profit tax are exempt from taxation. Dividends received from non-residents are included in taxable income of Ukrainian companies.

United Arab Emirates

Not applicable for this jurisdiction.

United Kingdom

Almost all dividends received from foreign subsidiaries are exempt from corporation tax except where anti-avoidance legislation applies. Capital gains recognized on the sale of shares in foreign or UK subsidiaries are exempt from tax provided that:

  • The subsidiary is a trading company (ie, one whose income is substantially derived from activities other than passive investment) or the holding company of either a trading group or a trading sub-group, and
  • The selling company has held the shares in the subsidiary for at least 12 months in the last 6 years

United States

Dividends received from foreign corporations may qualify for a 100% participation exemption, subject to ownership and holding period requirements. Dividends received from domestic corporations may qualify for a dividends received deduction, subject to ownership requirements.

Zimbabwe

Dividends remitted to non-resident shareholders from a local company are subject to withholding tax on dividends, and dividends earned by a resident shareholder from a local company are subject to dividends tax.