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%
|
|
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%
|
|
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 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
|
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 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
[As amended by Finance (No. 2) Act, 2014]
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