Surinam - Anti-abuse provisions

Surinam

Anti-abuse provision: Main purpose test

Article 10-2-a:

However, such dividends may be taxed in the State of which the company paying the dividends is a
resident, and according to the law of that State, but the tax so charged shall not exceed:

(a) 7.5 per cent of the gross amount of the dividends, if the recipient is a company whose capital is
divided, wholly or partly, into shares and which owns directly at least 25 per cent of the capital of the
company paying the dividends, provided that the relationship between the two companies is not
established or being maintained for the primary purpose of enjoying the benefit of the lower rate;