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Indian Withholding tax rates under provision of Double Taxation Avoidance Agreement

Contributed by Habibullah & Co
28 June, 2019


Country

Dividend
(not being covered under Section 115-O)

Interest

Royalty

Fee for Technical Services

Australia

15%

15%

10%/15%
[Note 2]

10%/15%
[Note 2]

Austria

10%

10%
[Note1]

10%

10%

Bangladesh

a) 10% (if at least 10% of the capital of the company paying the dividend is held by the recipient company);
b) 15% in all other cases

10%
[Note1]

10%

No separate provision

Belarus

a) 10%, if paid to a company holding 25% shares;
b) 15%, in all other cases

10%
[Note1]

15%

15%

Belgium

15%

15%
(10% if loan is granted by a bank)

10%

10%

Bhutan

10%

10%
[Note1]

10%

10%

Botswana

a) 7.5%, if shareholder is a company and holds at least 25% shares in the investee-company;
b) 10%, in all other cases

10%
[Note1]

10%

10%

Brazil

15%

15%
[Note1]

a) 25% for use of trademark;
b) 15% for others

15%

Bulgaria

15%

15%
[Note1]

a) 15% of royalty relating to literary, artistic, scientific works other than films or tapes used for radio or television broadcasting;
b) 20%, in other cases

20%

Canada

a) 15%, if at least 10% of the voting powers in the company, paying the dividends, is controlled by the recipient company;
b) 25%, in other cases

15%
[Note1]

10%-15%

10%-15%

China

10%

10%
[Note1]

10%

10%

Columbia

5%

10%
[Note1]

10%

10%

Croatia

a) 5% (if at least 10% of the capital of the company paying the dividend is held by the recipient company);
b) 15% in all other cases

10%
[Note1]

10%

10%

Cyprus

a) 10%, if at least 10% of the capital of the company paying dividend is held by the recipient company;
b) 15%, in all other cases

10%
[Note1]

15%

15%/10%

Czech Republic
[Note5]

10%

10%
[Note1]

10%

10%

Denmark

a) 15%, if at least 25% of the shares of the company paying the dividend is held by the recipient company;
b) 25%, in other cases

a) 10% if loan is granted by bank;
b) 15% for others
[Note1]

20%

20%

Finland

10%

10%
[Note1]

10%

10%

Fiji

5%

10%
[Note1]

10%

10%

France

10%

10%
[Note1]

10%

10%

Georgia

10%

10%
[Note1]

10%

10%

Germany

10%

10%
[Note1]

10%

10%

Hungary

10%

10%
[Note1]

10%

10%

Indonesia

10%

10%
[Note1]

10%

10%

Ireland

10%

10%
[Note1]

10%

10%

Israel

10%

10%
[Note1]

10%

10%

Italy

a) 15% if at least 10% of the shares of the company paying dividend is beneficially owned by the recipient company;
b) 25% in other cases

15%
[Note1]

20%

20%

Japan

10%

10%
[Note1]

10%

10%

Jordan

10%

10%
[Note1]

20%

20%

Kuwait

10%
[Note1]

10%

10%

10%

Kyrgyz Republic

10%

10%
[Note1]

15%

15%

Luxembourg

10%

10%
[Note1]

10%

10%

Malaysia

5%

10%
[Note1]

10%

10%

Malta

10%

10%
[Note1]

10%

10%

Mauritius

a) 5%, if at least 10% of the capital of the company paying the dividend is held by the recipient company;
b) 15%, in other cases

No Rates Specified

15%

No separate provision

Morocco

10%

10%
[Note1]

10%

10%

Mozambique

7.5%

10%
[Note1]

10%

No separate provision

Nepal

5%**, 10%

10%
[Note1]

15%

No separate provision

Netherlands

10%

10%
[Note1]

10%

10%

New Zealand

15%

10%
[Note1]

10%

10%

Norway

10%

10%
[Note1]

10%

10%

Oman

a) 10%, if at least 10% of shares are held by the recipient company;
b) 12.5%, in other cases

10%
[Note1]

15%

15%

Philippines

a) 15%, if at least 10% of the shares of the company paying the dividend is held by the recipient company;
b) 20%, in other cases

a) 10%, if interest is received by a financial institution or insurance company;
b) 15% in other cases
[Note1]

15% if it is payable in pursuance of any collaboration agreement approved by the Government of India

No separate provision

Poland

10%

10%
[Note1]

15%

15%

Qatar

a) 5%, if at least 10% of the shares of the company paying the dividend is held by the recipient company;
b) 10%, in other cases

10%
[Note1]

10%

10%

Romania

10%

10%
[Note1]

10%

10%

Russian Federation

10%

10%
[Note1]

10%

10%

Saudi Arabia

5%

10%
[Note1]

10%

No separate provision

Singapore

a) 10%, if at least 25% of the shares of the company paying the dividend is held by the recipient company;
b) 15%, in other cases

a) 10%, if loan is granted by a bank or similar institute including an insurance company;
b) 15%, in all other cases

10%

10%

South Africa

10%

10%
[Note1]

10%

10%

Spain

15%

15%
[Note1]

10%/20%
[Note3]

20%
[Note3]

Sri Lanka

7.5%

10%
[Note1]

10%

10%

Sweden

10%

10%
[Note1]

10%

10%

Swiss Confederation

10%

10%
[Note1]

10%

10%

Thailand

10%

10%
[Note1]

10%

No separate provision

Turkey

15%

a) 10% if loan is granted by a bank, etc.;
b) 15% in other cases
[Note1]

15%

15%

United Arab Emirates

10%

a) 5% if loan is granted by a bank/similar financial institute;
b) 12.5%, in other cases

10%

No separate provision

United Mexican States

10%

10%
[Note1]

10%

10%

United Kingdom

15%/10%
[Note4]

a) 10%, if interest is paid to a bank;
b) 15%, in other cases
[Note1]

10%/15%
[Note 2]

10%/15%
[Note 2]

United States

a) 15%, if at least 10% of the voting stock of the company paying the dividend is held by the recipient company;
b) 25% in other cases

a) 10% if loan is granted by a bank/similar institute including insurance company;
b) 15% for others

10%/15%
[Note 2]

10%/15%
[Note 2]

Vietnam

10%

10%
[Note 1]

10%

10%

 

* If the beneficial owner is a company (other than a partnership) which holds directly at least 10 per cent of the capital of the company paying the dividends.

** 5% if beneficial owner of shares is a company and it holds at least 10% of shares of the company paying the dividends.

*** if the beneficial owner is a company that, for an uninterrupted period of two fiscal years prior to the payment of the dividend, owns directly at least 25 per cent of the capital stock of the company paying the dividends.

****5% if recipient company owns at least 25% share in the company paying the dividend.

  1. Dividend/interest earned by the Government and certain specified institutions, inter-alia, Reserve Bank of India is exempt from taxation in the country of source (subject to certain condition).
  2. Royalties and fees for technical services would be taxable in the country of source at the rates prescribed for different categories of royalties and fees for technical services. These rates shall be subject to various conditions and nature of services/royalty for which payment is made. For detailed conditions refer to relevant Double Taxation Avoidance Agreements.
  3. Royalties and fees for technical services would be taxable in the country of source at the following rates:
    1. 10 per cent in case of royalties relating to the payments for the use of, or the right to use, industrial, commercial or scientific equipment;
    2. 20 per cent in case of fees for technical services and other royalties.
  4.  
    1. 15 per cent of the gross amount of the dividends where those dividends are paid out of income (including gains) derived directly or indirectly from immovable property within the meaning of Article 6 by an investment vehicle which distributes most of this income annually and whose income from such immovable property is exempted from tax;
    2. 10 per cent of the gross amount of the dividends, in all other cases
  5. The CBDT has clarified that DTAA signed with Government of the Czech Republic on the 27th January 1986 continues to be applicable to the residents of the Slovak Republic. [Notification No. 25, dated 23-03-2015]

[As amended by Finance Act, 2016]




 


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