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Friday, December 12, 2014

Countrywise Withholding tax rates / Chart as per DTAA


A person responsible for making payment to non-resident or foreign company is required to withhold tax. Tax is deductible at the rates prescribed under the Act or under the relevant DTAA, whichever is more beneficial for non-resident. This write up provides all such rates as prescribed under various Double Taxation Avoidance Agreements entered into between Indian and various foreign countries.
Withholding tax rates
Country
Dividend
(not being covered under Section 115-O)
Interest
Royalty
Fee forTechnical 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%
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%
Columbia5%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
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%
Hungary
10%
10% [Note1]
10%
10%
Indonesia
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]
15%
No separate provision
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%
Kazakstan
10%
10% [Note1]
10%
10%
Kenya
15%
15% [Note1]
20%
17.5%
Korea
a) 15%, if at least 20% of the capital of the company paying dividend is held by the recipient company;
b) 20%, in other cases
a) 10%, if interest is paid to a bank;
b) 15%, for others
[Note1]
15%
15%
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
No Rates Specified
15%
No separate provision
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
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 agreementapproved 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
a) 15%, if dividend is paid by an industrial company and at least 10% of capital of such company is held by the recipient company;
b) 20%, in other cases
a) 10%, if it is received by a financial institutions or insurance company;
b) 25% for others [Note1]
15%
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 ofpayment 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
[As amended by Finance (No. 2) Act, 2014] (Source- Income Tax Website)

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