# Malaysia's Double Taxation Agreement Network — Treaty Rates by Country

> Every Malaysian double taxation agreement in force, with its treaty withholding rates for interest, royalties and technical fees, the date it entered into force and its gazette order.

- Category: taxation
- Language: en
- Status: published
- Updated: 2026-07-20
- Canonical: https://negaraku.md/en/taxation/dta-network

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A treaty is a ceiling, never a floor. If the domestic rate under Schedule 1 of
the Income Tax Act 1967 is lower than the treaty rate, you withhold at the
domestic rate. Malaysia's domestic rates are 15 per cent on interest, 10 per
cent on royalties and 10 per cent on special classes of income under s.4A, so a
treaty showing 15 per cent interest buys nothing at all.

Every treaty shows NIL for dividends. That is not a negotiated concession — it
follows from the single-tier system, under which Malaysia imposes no withholding
tax on dividends paid to anyone.

Treaties take effect in Malaysia through an order made under s.132 and published
in the Federal Gazette. The gazette reference in the last column is the
instrument that gives the agreement force in Malaysian law.

## Rates by country

Rates are percentages. NIL means no tax under the agreement.

| Country | Dividends | Interest | Royalties | Technical fees | Treaty in force | Effective from | Gazette order |
| --- | --- | --- | --- | --- | --- | --- | --- |
| Albania | NIL | 10 | 10 | 10 | 21 August 1995 | 1 January 1996 | P.U.(A) 340/1994 |
| Australia | NIL | 15 | 10 | NIL | 26 June 1981 | 1 January 1980 | P.U.(A) 347/1980 |
| Austria | NIL | 15 | 10 | 10 | 1 December 1990 | 1 January 1988 | P.U.(A) 426/1989 |
| Bahrain | NIL | 5 | 8 | 10 | 31 July 2000 | 1 January 2001 | P.U.(A) 439/1999 |
| Bangladesh | NIL | 15 | 10 | 10 | 31 December 1984 | 1 January 1982 | P.U.(A) 113/1984 |
| Belgium | NIL | 15/10 (iv) | 10 | 10 | 14 August 1975 | 1 January 1976 | P.U.(A) 263/1976 |
| Bosnia and Herzegovina | NIL | 10 | 8 | 10 | 30 July 2012 | 1 January 2013 | P.U.(A) 341/2007 |
| Brunei | NIL | 10 | 10 | 10 | 17 June 2010 | 1 January 2011 | P.U.(A) 78/2010 |
| Cambodia | NIL | 10 | 10 | 10 | 28 December 2020 | 1 January 2021 | P.U.(A) 377/2019 |
| Canada | NIL | 15 | 10 | 10 | 18 December 1980 | 1 January 1981 | P.U.(A) 69/1977 |
| Chile | NIL | 15 | 10 | 5 | 25 August 2008 | 1 January 2009 | P.U.(A) 84/2005 |
| China | NIL | 10 | 10 | 10 | 14 September 1986 | 1 January 1988 | P.U.(A) 96/1986 |
| Croatia | NIL | 10 | 10 | 10 | 15 July 2004 | 1 January 2005 | P.U.(A) 426/2003 |
| Czech Republic | NIL | 12 | 10 | 10 | 31 March 1997 | 9 March 1998 | P.U.(A) 393/1996 |
| Denmark | NIL | 15 | 10 | 10 | 4 June 1971 | 1 January 1968 | P.U.(A) 86/1971 |
| Egypt | NIL | 15 | 10 | 10 | 9 July 2002 | 1 January 2004 | P.U.(A) 49/1998 |
| Fiji | NIL | 15 | 10 | 10 | 30 July 1997 | 1 January 1998 | P.U.(A) 209/1996 |
| Finland | NIL | 15 | 10 | 10 | 23 February 1986 | 1 January 1988 | P.U.(A) 353/1984 |
| France | NIL | 15 | 10 | 10 | 23 July 1976 | 1 January 1974 | P.U.(A) 243/1975 |
| Germany | NIL | 10 | 7 | 7 | 21 October 2010 | 1 January 2011 | P.U.(A) 193/2010 |
| Hong Kong | NIL | 10 | 8 | 5 | 28 December 2012 | 1 January 2013 | P.U.(A) 366/2012 |
| Hungary | NIL | 15 | 10 | 10 | 25 December 1992 | 1 January 1993 | P.U.(A) 425/1989 |
| India | NIL | 10 | 10 | 10 | 26 December 2012 | 1 January 2013 | P.U.(A) 338/2012 |
| Indonesia | NIL | 10 | 10 | 10 | 11 August 1992 | 1 January 1987 | P.U.(A) 31/1992 |
| Iran | NIL | 15 | 10 | 10 | 15 April 2005 | 1 January 2006 | P.U.(A) 59/2004 |
| Ireland | NIL | 10 | 8 | 10 | 11 September 1999 | 1 January 2000 | P.U.(A) 89/1999 |
| Italy | NIL | 15 | 10 | 10 | 18 April 1986 | 1 January 1977 | P.U.(A) 167/1984 |
| Japan | NIL | 10 | 10 | 10 | 31 December 1999 | 1 January 2000 | P.U.(A) 167/1999 |
| Jordan | NIL | 15 | 10 | 10 | 29 May 2000 | 1 January 2001 | P.U.(A) 190/1999 |
| Kazakhstan | NIL | 10 | 10 | 10 | 20 May 2010 | 1 January 2011 | P.U.(A) 228/2007 |
| Korea Republic | NIL | 15 | 10 | 10 | 2 January 1983 | 1 January 1983 | P.U.(A) 292/1982 |
| Kuwait | NIL | 10 | 10 | 10 | 29 May 2007 | 1 January 1988 | P.U.(A) 210/2006 |
| Kyrgyz Republic | NIL | 10 | 10 | 10 | 26 December 2006 | 1 January 2007 | P.U.(A) 449/2000 |
| Laos | NIL | 10 | 10 | 10 | 23 February 2011 | 1 January 2012 | P.U.(A) 379/2010 |
| Lebanon | NIL | 10 | 8 | 10 | 10 November 2004 | 1 January 2005 | P.U.(A) 418/2003 |
| Luxembourg | NIL | 10 | 8 | 8 | 29 December 2004 | 1 January 2005 | P.U.(A) 271/2003 |
| Malta | NIL | 15 | 10 | 10 | 1 September 2000 | 1 January 2002 | P.U.(A) 61/1996 |
| Mauritius | NIL | 15 | 10 | 10 | 19 August 1993 | 1 January 1991 | P.U.(A) 14/1993 |
| Mongolia | NIL | 10 | 10 | 10 | 7 November 1996 | 1 January 1997 | P.U.(A) 397/1995 |
| Morocco | NIL | 10 | 10 | 10 | 29 December 2006 | 1 January 2007 | P.U.(A) 61/2004 |
| Myanmar | NIL | 10 | 10 | 10 | 21 July 2008 | 1 January 2009 | P.U.(A) 302/1999 |
| Namibia | NIL | 10 | 5 | 5 | 13 December 2004 | 1 January 2005 | P.U.(A) 465/1999 |
| Netherlands | NIL | 10 | 8 | 8 | 2 February 1989 | 1 January 1986 | P.U.(A) 214/1988 |
| New Zealand | NIL | 15 | 10 | 10 | 2 September 1976 | 1 January 1975 | P.U.(A) 276/1976 |
| Norway | NIL | 15 | 10 | 10 | 9 September 1971 | 1 January 1968 | P.U.(A) 182/1972 |
| Pakistan | NIL | 15 | 10 | 10 | 9 November 1982 | 1 January 1980 | P.U.(A) 369/1982 |
| Papua New Guinea | NIL | 15 | 10 | 10 | 11 June 1999 | 1 January 2000 | P.U.(A) 327/1994 |
| Philippines | NIL | 15 | 10 | 10 | 27 July 1984 | 1 January 1985 | P.U.(A) 296/1982 |
| Poland | NIL | 10 | 8 | 8 | 12 January 2023 | 1 January 2024 | P.U.(A) 168/2014 and P.U.(A) 78/2022 |
| Qatar | NIL | 5 | 8 | 8 | 28 January 2009 | 1 January 2010 | P.U.(A) 405/2008 |
| Romania | NIL | 15 | 10 | 10 | 7 April 1984 | 1 January 1985 | P.U.(A) 156/1983 |
| Russia | NIL | 10 | 10 | 10 | 4 July 1988 | 1 January 1989 | P.U.(A) 58/1988 |
| San Marino | NIL | 10 | 10 | 10 | 28 December 2010 | 1 January 2011 | P.U.(A) 302/2010 |
| Saudi Arabia | NIL | 5 | 8 | 8 | 1 July 2007 | 1 January 2008 | P.U.(A) 225/2006 |
| Senegal | NIL | 10 | 10 | 10 | 1 January 2017 | 1 January 2017 | P.U.(A) 176/2010 |
| Seychelles | NIL | 10 | 10 | 10 | 10 July 2006 | 1 January 2007 | P.U.(A) 159/2004 |
| Singapore | NIL | 10 | 8 | 5 | 13 February 2006 | 1 January 2007 | P.U.(A) 200/2005 |
| Slovak Republic | NIL | 10 | 10 | 5 | 11 April 2016 | 1 January 2017 | P.U.(A) 256/2015 |
| South Africa | NIL | 10 | 5 | 5 | 6 July 2006 | 1 January 2007 | P.U.(A) 385/2005 |
| Spain | NIL | 10 | 7 | 5 | 28 December 2007 | 1 January 2008 | P.U.(A) 258/2007 |
| Sri Lanka | NIL | 10 | 10 | 10 | 13 August 1998 | 1 January 1999 | P.U.(A) 491/1997 |
| Sudan | NIL | 10 | 10 | 10 | 18 December 2002 | 1 January 2002 | P.U.(A) 354/1994 |
| Sweden | NIL | 10 | 8 | 8 | 28 January 2005 | 1 January 2006 | P.U.(A) 272/2003 |
| Switzerland | NIL | 10 | 10 | 10 | 12 November 1975 | 1 January 1974 | P.U.(A) 242/1975 |
| Syrian Arab Republic (Syria) | NIL | 10 | 10 | 10 | 31 August 2007 | 1 January 2008 | P.U.(A) 197/2007 |
| Thailand | NIL | 15 | 10 | 10 | 2 February 1983 | 1 January 1983 | P.U.(A) 157/1983 |
| Türkiye | NIL | 15 | 10 | 10 | 28 January 1997 | 1 January 1998 | P.U.(A) 489/1996 |
| Turkmenistan | NIL | 10 | 10 | NIL | 6 October 2009 | 1 January 2010 | P.U.(A) 218/2009 |
| Ukraine | NIL | 10 | 8 | 8 | 29 December 2021 | 1 January 2022 | P.U.(A) 223/2021 |
| United Arab Emirates | NIL | 5 | 10 | 10 | 18 September 1996 | 1 January 1996 | P.U.(A) 127/1996 |
| United Kingdom | NIL | 10 | 8 | 8 | 8 July 1998 | 1 January 1999 | P.U.(A) 251/1997 |
| Uzbekistan | NIL | 10 | 10 | 10 | 10 August 1999 | 1 January 2000 | P.U.(A) 88/1999 |
| Venezuela | NIL | 15 | 10 | 10 | 8 January 2008 | 1 January 2009 | P.U.(A) 175/2007 |
| Vietnam | NIL | 10 | 10 | 10 | 13 August 1996 | 1 January 1997 | P.U.(A) 60/1996 |
| Zimbabwe | NIL | 10 | 10 | 10 | 8 August 1996 | 1 January 1997 | P.U.(A) 124/1995 |

## Limited agreements and special arrangements

| Counterparty | Scope | Dividends | Interest | Royalties | Technical fees |
| --- | --- | --- | --- | --- | --- |
| Argentina | Limited — air and sea transport | NIL | 15 | 10 | 10 |
| United States of America | Limited — air and sea transport | NIL | 15 | 10 | 10 |
| Chinese Taipei | Arrangement via the Taipei Economic and Cultural Office | NIL | 10 | 10 | 7.5 |

A limited agreement covers only the income it names. Interest, royalties and
technical fees paid to a resident of Argentina or the United States fall back to
the domestic rates in the row below, because those categories are outside the
scope of the agreement.

For reference, the Malaysian domestic rates against which every treaty rate
should be compared:

| | Dividends | Interest | Royalties | Technical fees |
| --- | --- | --- | --- | --- |
| Malaysia domestic rate | NIL | 15 | 10 | 10 |

## Agreements signed but not yet in force

LHDN's page also lists agreements that have been signed and are awaiting entry
into force, including Belgium (signed 18 December 2009), Indonesia (19 July
2012), Kuwait (26 August 2010) and Seychelles (26 August 2010). These are
protocols or replacement agreements — the earlier treaty with each of those
counterparties continues to apply until the new instrument enters into force.

## The Multilateral Instrument overlay

Malaysia signed the Multilateral Convention to Implement Tax Treaty Related
Measures to Prevent Base Erosion and Profit Shifting on 24 January 2018. The
convention entered into force generally on 1 July 2018 and, for Malaysia's
treaties, from 1 June 2021.

The MLI does not amend a treaty the way a protocol does. It sits alongside the
treaty and modifies its application. LHDN publishes a **synthesised text** for
each modified treaty as a reading aid, and states expressly that the synthesised
text is not a source of law — the authentic treaty text and the MLI itself take
precedence.

Where a treaty has been modified, both parties' MLI positions matter. The
Malaysia–Japan synthesised text, for example, applies MLI Article 12 on
commissionaire arrangements and MLI Article 13 on the specific activity
exemptions, including the anti-fragmentation rule. A dozen or so treaties are
listed on LHDN's MLI page as not modified, either because the counterparty has
not signed or because positions do not match — Bangladesh, Brunei, Cambodia,
Norway, Philippines, Sri Lanka, Sudan and Switzerland among them.

Never quote a treaty article from the original text alone if the treaty appears
on the modified list. Read the synthesised text, then the MLI.

## How to use this table

1. Identify the income class under Malaysian law first — interest under s.109,
   royalty under s.109 with the s.2 definition, or special classes of income
   under s.4A charged by s.109B. Characterisation is domestic.
2. Compare the domestic rate with the treaty rate and apply the lower.
3. Obtain the payee's certificate of residence from its own tax authority before
   applying the treaty rate. Without it, withhold at the domestic rate.
4. If the treaty is MLI-modified, check the synthesised text for the article you
   are relying on, particularly the principal purpose test.
5. Where relief was not applied at source, the non-resident's remedy is a refund
   claim or the mutual agreement procedure, not a retrospective adjustment by
   the payer.

## What's next

If you are the Malaysian payer, `withholding-tax-rates` sets out the domestic
rate, form and remittance deadline for each payment type — that is the figure
you start from. If you are the Malaysian recipient of foreign income and need to
prove your own residence to a treaty partner, `certificate-of-residence` is the
application walkthrough.

## Sources

- Kadar Cukai Pegangan PPPDK — treaty withholding tax rates — https://www.hasil.gov.my/antarabangsa/perjanjian-pengelakan-pencukaian-dua-kali-pppdk/kadar-cukai-pegangan/ (LHDN)
- PPPDK Menyeluruh — comprehensive double taxation agreements — https://www.hasil.gov.my/antarabangsa/perjanjian-pengelakan-pencukaian-dua-kali-pppdk/pppdk-menyeluruh/ (LHDN)
- Instrumen Multilateral (MLI) — https://www.hasil.gov.my/antarabangsa/instrumen-multilateral-mli/ (LHDN)
- Income Tax Act 1967 (Act 53), reprint as at 21 May 2024 — s.132 — https://www.hasil.gov.my/wp-content/uploads/20240521-akta-cukai-pendapatan-1967-akta-53.pdf (LHDN)

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Source of truth: https://github.com/negaraku-md/NegaraKu.md
License: CC BY-SA 4.0