Investor Presentaiton
3. Mongolian Double Tax Treaties
Withholding
taxes
Domestic
Rates
UAE
Treaty
Dividends
20%
0%
Termination of DTTS
Kuwait
Treaty
0% for at least 49%
Luxembourg
Treaty
participation, 5% for
15/5/0 (3)
others
0% for financial
institutions, 10% for
others
5
Netherland
Treaty
0% for at least 10%
participation, 15% for
others
0% for financial
institutions, 10% for
others
5
10% for Financial
Interests
institutions, 20% for
0%
0%
others
20%
10%
10
Royalties
Technical
20%
Exempted
Exempted
5
Service
LO
5
The treaties became a loophole for treaty shopping and tax planning resulting unnecessary
revenue loss without contributing much to inbound investment;
Major investors in the Mining sector had been aggressively treaty shopping
Although the efforts to amend these treaties has undergone for about year, treaties has been
terminated unilaterally;
10View entire presentation