Tax rates as per IT Act vis a vis Tax Treaties (For Dividend)

Country	Dividend
Country	(not being covered under Section 115-O)
	Tax Treaty	I-T Act (Note 3)
	Tax Treaty	I-T Act (Note 3)
Albania	10%	20%/10%
Armenia	10%	20%/10%
Australia	15%	20%/10%
Austria	10%	20%/10%
Bangladesh	a) 10% (if at least 10% of the capital of the company paying the dividend is held by the recipient company);	20%/10%
Bangladesh	b) 15% in all other cases	20%/10%
Belarus	a) 10%, if paid to a company holding 25% shares;	20%/10%
Belarus	b) 15%, in all other cases	20%/10%
Belgium	15%	20%/10%
Bhutan	10%	20%/10%
Botswana	a) 7.5%, if shareholder is a company and holds at least 25% shares in the investee-company;	20%/10%
Botswana	b) 10%, in all other cases	20%/10%
Brazil	15%	20%/10%
Bulgaria	15%	20%/10%
Canada	a) 15%, if at least 10% of the voting powers in the company, paying the dividends, is controlled by the recipient company;	20%/10%
Canada	b) 25%, in other cases	20%/10%
China	10%	20%/10%
Columbia	5%	20%/10%
Croatia	a) 5% (if at least 10% of the capital of the company paying the dividend is held by the recipient company);	20%/10%
Croatia	b) 15% in all other cases	20%/10%
Cyprus	a) 10%, if at least 10% of the capital of the company paying dividend is held by the recipient company;	20%/10%
Cyprus	b) 15%, in all other cases	20%/10%
Czech Republic [Note4]	10%	20%/10%
Denmark	a) 15%, if at least 25% of the shares of the company paying the dividend is held by the recipient company;	20%/10%
Denmark	b) 25%, in other cases	20%/10%
Estonia	10%	20%/10%
Ethiopia	7.50%	20%/10%
Finland	10%	20%/10%
Fiji	5%	20%/10%`
France	10%	20%/10%
Georgia	10%	20%/10%
Germany	10%	20%/10%
Hungary	10%	20%/10%
Indonesia	a) 10%, if at least 25% of the shares of the company paying the dividend is held by the recipient company;	20%/10%
Indonesia	b) 15%, in other cases	20%/10%
Iceland	10%	20%/10%
Ireland	10%	20%/10%
Israel	10%	20%/10%
Italy	a) 15% if at least 10% of the shares of the company paying dividend is beneficially owned by the recipient company;	20%/10%
Italy	b) 25% in other cases	20%/10%
Japan	10%	20%/10%
Jordan	10%	20%/10%
Kazakhstan	10%	20%/10%
Kenya	15%	20%/10%
Korea	a) 15%, if at least 20% of the capital of the company paying dividend is held by the recipient company;	20%/10%
Korea	b) 20%, in other cases	20%/10%
Kuwait	10% [Note 1]	20%/10%
Kyrgyz Republic	10%	20%/10%
Latvia	10%	20%/10%
Lithuania	5%*, 15%	20%/10%
Luxembourg	10%	20%/10%
Malaysia	5%	20%/10%
Malta	10%	20%/10%
Mongolia	15%	20%/10%
Mauritius	a) 5%, if at least 10% of the capital of the company paying the dividend is held by the recipient company;	20%/10%
Mauritius	b) 15%, in other cases	20%/10%
Montenegro	5% (in some cases 15%)	20%/10%
Myanmar	5%	20%/10%
Morocco	10%	20%/10%
Mozambique	7.50%	20%/10%
Namibia	10%	20%/10%
Nepal	5%**, 10%	20%/10%
Netherlands	10%	20%/10%
New Zealand	15%	20%/10%
Norway	10%	20%/10%
Oman	a) 10%, if at least 10% of shares are held by the recipient company;	20%/10%
Oman	b) 12.5%, in other cases	20%/10%
Philippines	a) 15%, if at least 10% of the shares of the company paying the dividend is held by the recipient company;	20%/10%
Philippines	b) 20%, in other cases	20%/10%
Poland	10%	20%/10%
Portuguese Republic	10%***/15%	20%/10%
Qatar	a) 5%, if at least 10% of the shares of the company paying the dividend is held by the recipient company;	20%/10%
Qatar	b) 10%, in other cases	20%/10%
Romania	10%	20%/10%
Russian Federation	10%	20%/10%
Saudi Arabia	5%	20%/10%
Serbia	a) 5%, if recipient is company and holds 25% shares;	20%/10%
Serbia	b) 15%, in any other case	20%/10%
Singapore	a) 10%, if at least 25% of the shares of the company paying the dividend is held by the recipient company;	20%/10%
Singapore	b) 15%, in other cases	20%/10%
Slovenia	a) 5%, if at least 10% of the shares of the company paying the dividend is held by the recipient company;	20%/10%
Slovenia	b) 15%, in other cases	20%/10%
South Africa	10%	20%/10%
Spain	15%	20%/10%
Sri Lanka	7.50%	20%/10%
Sudan	10%	20%/10%
Sweden	10%	20%/10%
Swiss	10%	20%/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;	20%/10%
Syrian Arab Republic	b) 10%, in other cases	20%/10%
Tajikistan	a) 5%, if at least 25% of the shares of the company paying the dividend is held by the recipient company;	20%/10%
Tajikistan	b) 10%, in other cases	20%/10%
Tanzania	5%****, 10%	20%/10%
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;	20%/10%
Thailand	b) 20%, in other cases	20%/10%
Trinidad and Tobago	10%	20%/10%
Turkey	15%	20%/10%
Turkey	15%	20%/10%
Turkmenistan	10%	20%/10%
Uganda	10%	20%/10%
Ukraine	a) 10%, if at least 25% of the shares of the company paying the dividend is held by the recipient company;	20%/10%
Ukraine	b) 15%, in other cases	20%/10%
United Arab Emirates	10%	20%/10%
United Arab Emirates	10%	20%/10%
United Mexican States	10%
United Kingdom	15%/10%	20%/10%
United Kingdom	(Note 2)	20%/10%
United States	a) 15%, if at least 10% of the voting stock of the company paying the dividend is held by the recipient company;	20%/10%
United States	b) 25% in other cases	20%/10%
Uruguay	5%	20%/10%
Uzbekistan	10%	20%/10%
Vietnam	10%	20%/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;	20%/10%
Zambia	b) 15% in other cases	20%/10%

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.

2. (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

3. (a) Rate of tax shall be 10% on income from Global Depository Receipts under Section 115AC(1)(b) of Income-tax Act, 1961 (other than dividends referred to in section 115-O).

(b) Rate of tax shall be 20% under Section 115A on dividend (other than dividends referred to in section 115-O) received by a foreign company or a non-resident non-corporate assessee

(c) Rate of tax shall be 20% under Section 115AD on dividend (other than dividends referred to in section 115-O) received by a Foreign institutional investor.

4. 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]

*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.

Author: Himanshi

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