DTAA rates applicable for various countries

Hello, in this post we will discuss the DTAA rates applicable for various countries. We will cover the following:

Introduction to Double Taxation Avoidance Agreement or DTAA

The Double Taxation Avoidance Agreement or DTAA is a treaty signed between two countries i.e., India and another country (any two/multiple countries).  The agreement is signed in order to make a country an attractive destination and taxpayers can avoid paying taxes multiple times on their income earned from the source country as well as residence country. Currently, India has DTAA treaties with more than 80 countries in the world.

Countries with which India has DTAA

The description of the Note 1, Note 2 Note 3 and Note 4 given in the table are given below.

Sl No Country Name Dividend (not being covered u/s 115-O) Interest Royalty Fee for Technical Services
1 Albania 10% 10% (Note1) 10% 10%
2 Armenia 10% 10% (Note1) 10% 10%
3 Australia 15% 15% 10% / 15% (Note 2) 10% / 15% (Note 2)
4 Austria 10% 10% (Note1) 10% 10%
5 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
6 Belarus a) 10%, if paid to a company holding 25% shares;

b) 15%, in all other cases

10% (Note1) 15% 15%
7 Belgium 10% 10% (Note1) 10% 10%
8 Botswana a) 7.5%, if the shareholder is a company and holds at least 25% of shares in the investee company;

b) 10%, in all other cases

10% (Note1) 10% 10%
9 Brazil 15% 15% (Note 1) a) 25% for use of the trademark;

b) 15% for others

No separate provision
10 Bulgaria 15% 15% (Note 1) 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%
11 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% (Note 1) 10%-15% 10%-15%
12 China 10% 10% (Note 1) 10% 10%
13 Columbia 10% 10% (Note 1) 10% 10%
14 Czech Republic [Note5] 10% 10% (Note 1) 10% 10%
15 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 the loan is granted by the bank;

b) 15% for others (Note1)

20% 20%
16 Estonia 10% a) 10% (Note 1) 10% 10%
17 Ethiopia 7.5% 10% (Note 1) 10% 10%
18 Finland 10% 10% (Note1) 10% 10%
19 Fiji 5% 10% (Note1) 10% 10%
20 France 10% 10% (Note1) 10% 10%
21 Georgia 10% 10% (Note1) 10% 10%
22 Germany 10% 10% (Note1) 10% 10%
23 HongKong 5% 10% (Note1) 10% 10%
24 Hungary 10% 10% (Note1) 10% 10%
25 Indonesia 10% 10% (Note1) 10% 10%
26 Iceland 10% 10% (Note1) 10% 10%
27 Ireland 10% 10% (Note1) 10% 10%
28 Israel 10% 10% (Note1) 10% 10%
29 Italy a) 15% if at least 10% of the shares of the company paying a dividend is beneficially owned by the recipient company.

b) 25% in other cases

10% (Note1) 20% 20%
30 Japan 10% 10% (Note1) 10% 10%
31 Jordan 10% 10% (Note1) 20% 20%
32 Kazakhstan 10% 10% (Note1) 10% 10%
33 Kenya 10% 10% 10% 10%
34 Korea 15% 10% 10% 10%
35 Kuwait 10% (Note1) 10% 10% 10%
36 Kyrgyz Republic 10% 10% (Note1) 15% 15%
37 Latvia 10% 10% (Note1) 10% 10%
38 Lithuania 5%*, 15% 10% (Note1) 10% 10%
39 Luxembourg 10% 10% (Note1) 10% 10%
40 Malaysia 5% 10% (Note1) 10% 10%
41 Malta 10% 10% (Note1) 10% 10%
42 Mongolia 15% 15% (Note1) 15% 15%
43 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%
44 Montenegro 5% (in some cases 15%) 10% (Note1) 10% 10%
45 Myanmar 5% 10% (Note1) 10% No separate provision
46 Morocco 10% 10% (Note1) 10% 10%
47 Mozambique 7.5% 10% (Note1) 10% No separate provision
48 Macedonia 10% 10% (Note1) 10% 10%
49 Namibia 10% 10% (Note1) 10% 10%
50 Nepal 5%**, 10% 10% (Note1) 15% No separate provision
51 Netherlands 10% 10% (Note1) 10% 10%
52 New Zealand 15% 10% (Note1) 10% 10%
53 Norway 10% 10% (Note1) 10% 10%
54 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%
55 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
56 Poland 10% 10% (Note1) 15% 15%
57 Portuguese Republic 10%***/15% 10% 10% 10%
58 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%
59 Romania 10% 10% (Note1) 10% 10%
60 Russian Federation 10% 10% (Note1) 10% 10%
61 Saudi Arabia 5% 10% (Note1) 10% No separate provision
62 Serbia a) 5%, if recipient is company and holds 25% shares;

b) 15%, in any other case

10% (Note1) 10% 10%
63 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%
64 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%
65 South Africa 10% 10% (Note1) 10% 10%
66 Sri Lanka 7.5% 15% (Note1) 10%/20%[Note 3] 20%[Note 3]
67 Sudan 10% 10% (Note1) 10% 10%
68 Sweden 10% 10% (Note1) 10% 10%
69 Swiss Confederation 10% 10% (Note1) 10% 10%
70 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
71 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
72 Tanzania 5%****, 10% 10% 10% No separate provision
73 Thailand 10% 10% (Note1) 10% No separate provision
74 Trinidad and Tobago 10% 10% (Note1) 10% 10%
75 Turkey 15% a) 10% if loan is granted by a bank, etc.;b) 15% in other cases [Note1] 15% 15%
76 Turkmenistan 10% 10% (Note1) 10% 10%
77 Uganda 10% 10% (Note1) 10% 10%
78 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%
79 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
80 United Mexican States 10% 10% (Note1) 10% 10%
81 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]
82 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]
83 Uruguay 5% 10% (Note1) 10% 10%
84 Uzbekistan 10% 10% (Note1) 10% 10%
85 Vietnam 10% 10% (Note1) 10% 10%
86 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% of the capital of the company paying the dividends.

**5% if the 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% of the capital stock of the company paying the dividends.

****5% if the recipient company owns at least 25% share in the company paying the dividend.

Note 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 the source (subject to certain condition).

Note 2 – Royalties and fees for technical services would be taxable in the country of the 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.

Note 3 – Royalties and fees for technical services would be taxable in the country of the source at the following rates:

  • 10% in case of royalties relating to the payments for the use of, or the right to use industrial, commercial or scientific equipment;
  • 20% in case of fees for technical services and other royalties.

Note 4

  • 15% 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;
  • 10% of the gross amount of the dividends, in all other cases

Note 5 – The Central Board of Direct Taxes 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]

This ends the post on DTAA rates applicable for various countries. Let us know your opinion by commenting below.

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