Withholding Tax rate of 5% on payment of dividend to resident of Netherlands after applying MFN Clause

Concentrix Services Netherlands B.V. Vs ITO (TDS) (Delhi High Court)

Withholding Tax rate of 5% on payment of dividend to resident of Netherlands after applying MFN Clause

The Hon’ble Delhi High Court in the case of Concentrix Services Netherland B.V. Vs. ITO (TDS) & Ors held that withholding tax rate of 5% is to be applied while making payment of dividend by Indian entity to its shareholder in Netherlands after applying the Most Favoured Nation (MFN) clause in the Tax Treaty between India and Netherlands.

Facts of the case, contention raised by the Tax Department and decision of the Hon’ble High Court is as under:-

Facts

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