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On 16 March 2026, Decision of the Council of Ministers No. 4 of 2026 entered into force. The Decision introduces a mechanism allowing the direct application of withholding tax rates under double tax treaties.
Under the previous practice, withholding tax was generally applied at the domestic rates set out in the Income Tax Law, with non-resident recipients subsequently required to claim treaty relief through a refund procedure. The new provisions allow treaty benefits to be applied at source, subject to specific conditions and procedural requirements.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
