Withholding tax rates
Country
|
Dividend
(not being covered
under Section 115-O)
|
Interest
|
Royalty
|
Fee for Technical
Services
|
Albania
|
10%
|
10%[Note1]
|
10%
|
10%
|
Armenia
|
10%
|
10% [Note1]
|
10%
|
10%
|
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% [Note 1]
|
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
|
No separate provision
|
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]
|
15%-20%
|
15%-20%
|
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
|
10%
|
10% [Note1]
|
10%
|
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%
|
Estonia
|
10%
|
10% [Note1]
|
10%
|
10%
|
Ethiopia
|
7.5%
|
10% [Note1]
|
10%
|
10%
|
Finland
|
10%
|
10% [Note1]
|
10%
|
10%
|
Fiji
|
5%
|
10% [Note 1]
|
10%
|
10%
|
France
|
10%
|
10% [Note1]
|
10%
|
10%
|
Georgia
|
10%
|
10% [Note1]
|
10%
|
10%
|
Germany
|
10%
|
10% [Note1]
|
10%
|
10%
|
Hongkong
|
5%
|
10% [Note1]
|
10%
|
10%
|
Hungary
|
10%
|
10% [Note1]
|
10%
|
10%
|
Indonesia
|
10%
|
10% [Note1]
|
10%
|
10%
|
Iceland
|
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%
|
Kazakhstan
|
10%
|
10% [Note1]
|
10%
|
10%
|
Kenya
|
10%
|
10%
|
10%
|
10%
|
Korea
|
15%
|
10%
|
10%
|
10%
|
Kuwait
|
10% [Note 1]
|
10%
|
10%
|
10%
|
Kyrgyz Republic
|
10%
|
10% [Note1]
|
15%
|
15%
|
Latvia
|
10%
|
10% [Note1]
|
10%
|
10%
|
Lithuania
|
5%*, 15%
|
10% [Note1]
|
10%
|
10%
|
Luxembourg
|
10%
|
10% [Note1]
|
10%
|
10%
|
Malaysia
|
5%
|
10% [Note1]
|
10%
|
10%
|
Malta
|
10%
|
10% [Note1]
|
10%
|
10%
|
Mongolia
|
15%
|
15% [Note1]
|
15%
|
15%
|
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
|
7.5
|
15%
|
10%
|
Montenegro
|
5% (in some cases 15%)
|
10% [Note1]
|
10%
|
10%
|
Myanmar
|
5%
|
10% [Note1]
|
10%
|
No separate provision
|
Morocco
|
10%
|
10% [Note1]
|
10%
|
10%
|
Mozambique
|
7.5%
|
10% [Note1]
|
10%
|
No separate provision
|
Macedonia
|
10%
|
10% [Note 1]
|
10%
|
10%
|
Namibia
|
10%
|
10% [Note1]
|
10%
|
10%
|
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%
|
Portuguese Republic
|
10%***/15%
|
10%
|
10%
|
10%
|
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
|
Serbia
|
a) 5%, if recipient is company and holds 25% shares;
b) 15%, in any other case
|
10% [Note1]
|
10%
|
10%
|
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%
|
Slovenia
|
a) 5%, if at least 10% of the shares of the company paying the
dividend is held by the recipient company;
b) 15%, in other cases
|
10%
|
10%
|
10%
|
South Africa
|
10%
|
10% [Note1]
|
10%
|
10%
|
Spain
|
15%
|
15% [Note1]
|
10%/20%
[Note 3]
|
20%
[Note 3]
|
Sri Lanka
|
7.5%
|
10% [Note1]
|
10%
|
10%
|
Sudan
|
10%
|
10%[Note1]
|
10%
|
10%
|
Sweden
|
10%
|
10% [Note1]
|
10%
|
10%
|
Swiss Confederation
|
10%
|
10%[Note1]
|
10%
|
10%
|
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
|
10%[Note1]
|
10%
|
No separate provision
|
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
|
10%[Note1]
|
10%
|
No separate provision
|
Tanzania
|
5%****, 10%
|
10%
|
10%
|
No separate provision
|
Thailand
|
10%
|
10% [Note1]
|
10%
|
No separate provision
|
Trinidad and Tobago
|
10%
|
10% [Note1]
|
10%
|
10%
|
Turkey
|
15%
|
a) 10% if loan is granted by a bank, etc.;
b) 15% in other cases
[Note1]
|
15%
|
15%
|
Turkmenistan
|
10%
|
10% [Note1]
|
10%
|
10%
|
Uganda
|
10%
|
10%[Note1]
|
10%
|
10%
|
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
|
10% [Note1]
|
10%
|
10%
|
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%
(Note 4)
|
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]
|
Uruguay
|
5%
|
10% [Note1]
|
10%
|
10%
|
Uzbekistan
|
10%
|
10% [Note1]
|
10%
|
10%
|
Vietnam
|
10%
|
10% [Note1]
|
10%
|
10%
|
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
|
10% [Note1]
|
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:
a. 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;
b. 20 per cent in case of fees for technical services and other
royalties.
4. (a)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;
(b) 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]
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