Disclaimer:

The contents of this document are for information purposes only. This aims to enable public to have a quick and an easy access to information and do not purport to be legal documents.

 

Viewers are advised to verify the content from Government Acts/Rules/Notifications etc.

  

Tax rates as per IT Act vis a vis Tax Treaties

  

Country

Dividend

Interest

 

Royalty

 

Fee for Technical Services

 

 

Tax Treaty

I-T Act (Note 1)

Tax Treaty

I-T Act

(Note 2)

Tax Treaty

I-T Act (Note 3)

Tax Treaty

I-T Act

(Note 3)

Albania

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Armenia

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Australia

15%

20%/10%

15%

20%/10%/5%

10%/15%

20%

No separate provision

20%

Austria

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

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

20%/10%

10%

20%/10%/5%

10%

20%

No separate provision

20%

Belarus

a) 10%, if paid to a company holding 25% shares;

b) 15%, in all other cases

20%/10%

10%

20%/10%/5%

15%

20%

15%

20%

Belgium

15%

20%/10%

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

20%/10%/5%

10%

20%

10%

20%

Bhutan

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

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

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Brazil

15%

20%/10%

15%

20%/10%/5%

25% for use of trademark; 15% for others

20%

No separate provision

20%

Bulgaria

15%

20%/10%

15%

20%/10%/5%

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

20%

20%

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

20%/10%

15%

20%/10%/5%

10%-20%

20%

10%-20%

20%

China

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Colombia

5%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

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

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Cyprus

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Czech Republic [Note8]

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

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

20%/10%

a) 10% if loan is granted by bank;

b) 15% for others

20%/10%/5%

20%

20%

20%

20%

Estonia

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Ethiopia

7.5%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Finland

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Fiji

5%

20%/10%`

10%

20%/10%/5%

10%

20%

10%

20%

France

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Georgia

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Germany

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Greece

20%

20%/10%

20%

20%/10%/5%

10%

20%

No separate provision

20%

Hongkong

5%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Hungary

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Indonesia

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Iceland

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Ireland

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Iran

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Israel

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

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

20%/10%

15%

20%/10%/5%

20%

20%

20%

20%

Japan

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Jordan

10%

20%/10%

10%

20%/10%/5%

20%

20%

20%

20%

Kazakhstan

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Kenya

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Korea

15%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Kuwait

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Kyrgyz Republic

10%

20%/10%

10%

20%/10%/5%

15%

10%

15%

20%

Libyan Arab Jamahiriya

10% 20%

20%/10%

20%

20%/10%/5%

20%

20%

No separate provision

20%

Latvia

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Lithuania

a) 5%, 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.

b) 15%, in other cases

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Luxembourg

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Malaysia

5%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Malta

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Mongolia

15%

20%/10%

15%

20%/10%/5%

15%

20%

15%

20%

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

20%/10%

7.5%

20%/10%/5%

15%

20%

10%

20%

Montenegro

(a ) 5% if the beneficial owner is a company (other than a partnership) which holds directly at least 25 per cent of the capital of the company paying the dividends;

(b ) 15% in other cases

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Myanmar

5%

20%/10%

10%

20%/10%/5%

10%

20%

No separate provision

20%

Morocco

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Mozambique

7.5%

20%/10%

10%

20%/10%/5%

10%

20%

No separate provision

20%

Macedonia 10% 20%/10% 10% 20%/10%/5% 10% 20% 10% 20%

Namibia

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Nepal

(a) 5% if the beneficial owner is a company which owns at least 10 per cent of the shares of the company paying the dividends;

(b) 15% in all other cases.

20%/10%

10%

20%/10%/5%

15%

20%

No separate provision

20%

Netherlands

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

New Zealand

15%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Norway

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Oman

a) 10%, if at least 10% of shares are held by the recipient company;

b) 12.5%, in other cases

20%/10%

10%

20%/10%/5%

15%

20%

15%

20%

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

20%/10%

a) 10%, if interest is received by a financial institution or insurance company;

b) 15% in other cases

20%/10%/5%

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

20%

No separate provision

20%

Poland

10%

20%/10%

10%

20%/10%/5%

22.5%

20%

22.5%

10%

Portuguese Republic

10%***/15%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Qatar

a) 5% if the beneficial owner is a company which owns at least ten per cent of the shares of the company paying the dividend; and

b) 10% in all other cases.

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Romania

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Russian Federation

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Saudi Arabia

5%

20%/10%

10%

20%/10%/5%

10%

20%

No separate provision

20%

Serbia

a) 5%, if recipient is company and holds 25% shares;

b) 15%, in any other case

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

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

20%/10%

a) 10%, if loan is granted by a bank or similar institute including an insurance company;

b) 15%, in all other cases

20%/10%/5%

10%

20%

10%

20%

Slovenia

a) 5% if the beneficial owner is a company which owns at least ten per cent of the shares of the company paying the dividend; and

b)15% in all other cases

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

South Africa

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Spain

15%

20%/10%

15%

20%/10%/5%

10%

20%

10%

20%

Sri Lanka

7.5%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Sudan

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Sweden

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Swiss

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Syrian Arab Republic

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

20%/10%

10%

20%/10%/5%

10%

20%

No separate provision

20%

Taipei

12.5%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Tajikistan

a) 5%, if at least 25% of the shares of the company paying the dividend is held by the recipient company;

b) 10%, in other cases

20%/10%

10%

20%/10%/5%

10%

20%

No separate provision

20%

Tanzania

10% (5% if shareholder is a company and holds 25% shares)

20%/10%

10%

20%/10%/5%

10%

20%

No separate provision

20%

Thailand

10%

20%/10%

10%

20%/10%/5%

10%

20%

No separate provision

20%

Trinidad and Tobago

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Turkey

15%

20%/10%

a) 10% if loan is granted by a bank, etc.;

b) 15% in other cases

 

20%/10%/5%

15%

20%

15%

20%

Turkmenistan

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Uganda

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Ukraine

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

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

United Arab Emirates

10%

20%/10%

a) 5% if loan is granted by a bank/similar financial institute;

b) 12.5%, in other cases

20%/10%/5%

10%

20%

No separate provision

20%

United Arab Republic (EGPT)10%/20% [Note 4]20%/10%20% [Note 4]20%/10%/5%20% [Note 4]20%No separate provision20%

United Mexican States

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

United Kingdom

(a) 15% o where 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

(b ) 10% in all other case

(Note 5)

20%/10%

a) 10%, if interest is paid to a bank;

b) 15%, in other cases

20%/10%/5%

10%/15%

20%

10%/15%

20%

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

20%/10%

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

b) 15% for others

20%/10%/5%

10%/15%

20%

10%/15%

20%

Uruguay

5%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Uzbekistan

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Vietnam

10%

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Zambia

a) 5%, if at least 25% of the shares of the company paying the dividend is held by a recipient company for a period of at least 6 months prior to the date of payment of the dividend;

b) 15% in other cases

20%/10%

10%

20%/10%/5%

10%

20%

10%

20%

Notes:

1) Dividend:

a) Rate of tax shall be 10% on income from Global Depository Receipts under Section 115AC(1)(b) of Income-tax Act, 1961.

b) Rate of tax shall be 20% under Section 115A on dividend received by a foreign company or a non-resident non-corporate assessee. However, rate of tax shall be 10% on dividend received from a unit in an IFSC as referred to in section 80LA(1A).

c) Rate of tax shall be 20% under Section 115AD on dividend received by a Foreign institutional investor.

2) Interest

a) Rate of tax shall be 20% under Section 115A on interest received by a foreign company or a non-resident non-corporate assessee from Government or an Indian concern on moneys borrowed or debt incurred by Government or the Indian concern in foreign currency.

b) Rate of tax shall be 10% under Section 115AC on income from bonds of an Indian company issued in accordance with such scheme as the Central Government may, by notification in the Official Gazette, specify in this behalf, or on bonds of a public sector company sold by the Government, and purchased by non-resident in foreign currency

c) Rate of tax shall be 5% in following cases:

(i) Interest received from an infrastructure debt fund as referred to in section 10(47)

(ii) Interest received from an Indian company specified in section 194LC.

(iii) Interest of the nature and extent referred to in section 194LD (applicable from the assessment year 2014-15).

(iv) Distributed income being interest referred to in section 194LBA(2) (section 194LBA is inserted by the Finance (No. 2) Act, 2014 w.e.f. 01-10-2014)

3. 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.

From Assessment Year 2017-18, any income of a person resident in India by way of royalty in respect of a patent developed and registered in India shall be taxable at the rate of 10% as per section 115BBF,

4. Articles 11, 12 and 13 of the India-UAR (Egypt) treaty don’t provide withholding tax rates in respect of dividend, interest and royalty payments. Thus, the tax shall be withheld as per rates applicable under the Income-tax Act 1961.

 

 

[As amended by Finance (No. 2) Act, 2024]