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.

Article compiles Country wise Withholding tax rate on Dividend (not being covered under Section 115-O), Interest, Royalty and Fee for Technical Services as updated with amendment carried out by Finance Act, 2018

Country-wise / Income Wise Withholding Tax Rate Chart for Financial Year 2018-19

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%
Bhutan 10% 10% [Note 1] 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

No separate provision
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%
Croatia a) 5% (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% 10%
Cyprus 10% 10% [Note1] 10% 10%
Czech Republic [Note5] 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 10% 10% [Note1] 10% 10%
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%
Kazakhstan 10% 10% [Note1] 10% 10%
Kenya 10% 10% 10% 10%
Korea 15% 10% 10% 10%
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

7.5 15% 10%
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
Macedonia 10% 10% [Note 1] 10% 10%
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 10% 10% [Note1] 10% 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

5. 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]

 [Republished as per amendments vide Finance Act, 2017, Source- Income Tax Website)

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15 responses to “Countrywise Withholding tax rates / Chart as per DTAA”

  1. Vaibhav Ghiya says:

    can i get the same chart for Singapore as well ?

  2. behl dinesh says:

    rate of with holding tax for technical services between india and uae
    and between india and saudi arabia for technical services

  3. behl dinesh says:

    What is the rate of withholding tax between india and UAE and saudi arabia

  4. Shubham Agarwal says:

    As per revised DTTA with Kenya dated 19-02-2018, withholding tax on Fee for Technical Services is 10% instead of 17.5%

  5. Jagadeesh N Aremane says:

    Hi,

    I wanted know about tax rate b/w India & Singapore, Specifically Service Charges of Training Expense & Professional Charges , Singapore company don’t have INDIA PAN, TRC 10F in this case please advice tax rate

  6. Manohar M says:

    Royalties in Malaysia Country as per DTAA deducted 10%.
    PAN Number of Foreign Party is require?

  7. Bairavamoorthy says:

    sir, annual membership fees paid to Switzerland, whether TDS is applicable for this remittance. if not what are the relevant article of DTAA

  8. venkataramu says:

    PLZ ADVISE

    WHAT IS THE WITHHOLDING TAX RATE FOR AY 16-17 FOR TECHNICAL KNOW HOW FEES PAYABLE TO GERMANY THEY DON’T HAVE PE IN INDIA

    RGDS

  9. Varghese says:

    Percentage of Withholding tax against Royalty payment to Hong Kong company before 1st April`2015 and after 1st April`2015.

    Please revert back urgently.

  10. VYSHNAVI LAKKANIKI says:

    Sir, IF 115-O IS APPLICABLE PLEASE SUGGEST THE RATES FOR THE COMPANY

  11. adv. dr.g.balakrishnan says:

    SUGGEST ALL TRIBUNALS NEED TO FOLLOW IN THE INTEREST OF JUSTICE, ELSE PEOPLE WOULD LOSE CONFIDENCE ON TRIBUNALS,AND THE PEOPLE WOULD GO TO THE HIGH COURTS UNDER ART 226 OR ART 32.. SO HOPE HON TRIBUNALS HONORABLY FOLLOW STRICTLY THR PRINCIPLES OF NATURAL JUSTICE AND RULE OF LAW WHICH ARE PRIMARY REQUIREMENT IN ANY COUNTRY.

  12. Madhusudan says:

    thnx for sharing….

  13. adv. dr.g.balakrishnan says:

    good advisory. thanks

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