Detail Table of withholding tax in India under DTA agreement

Dividend [not being covered by section 115-O]

Interest

Royalty

Fees for technical service

Right of State to tax

Tax rate

Right of State to tax

Tax rate

Right of State to tax

Tax rate

Right of State to tax

Tax rate

Armenia

Both

10%

Both

10%

Both

10%

Both

10%

Australia

Both

15%

Both

15%

Both

[Note 3]

Both

[Note 3]

Austria

Both

10%

Both

10%

Both

10%

Both

10%

Bangladesh

Both

10% (if at least 10% of the capital of the company paying the dividend is held by the recipient)

Both

10% [Note 2

Both

10%

No separate provision

Belarus

Both

10% if paid to a company holding 25% shares; otherwise 15%

Both

10% [Note 2

Both

15%

Both

15%

Belgium

Both

15%

Both

15% (10% if granted by a bank)

Both

10%

Both

10%

Brazil

Both

15%

Both

15% [Note 2]

Both

25% for use of
trademark; 15% for others

No separate provision

Bulgaria

Both

15%

Both

15% [Note 2]

Both

15% of royalty relating to literary, artistic, scientific works
other than films or
tapes used
for radio or television broad-casting;
20% in other cases

Both

20%

Canada

Both

15% if at least 10% of the shares of the company paying the dividends is held by the recipient of dividend; 25% in other cases

Both

15% [Note 2]

Both

10%-20%

Both

10%-20%

China

Both

10%

Both

10% [Note 2]

Both

10%

Both

10%

Cyprus

Both

10% if at least 10% of the capital of the company paying dividend is held by the recipient, 15% in all other cases

Both

10% [Note 2]

Both

15%

Both

10%

Czeck Republic

Both

10%

Both

10% [Note 2]

Both

10%

Both

10%

Denmark

Both

15% if at least 25%
of the shares of the company paying the dividend is held by the recipient; 20% in other cases

Both

10% if loan is granted
by bank; 15% for others [Note 2]

Both

20%

Both

20%

Germany

Both

10%

Both

10% [Note 2]

Both

10%

Both

10%

Finland

Both

15%

Both

10% [Note 2]

Both

15%-20% during 1997-2001, 15% for subsequent years; 10% for equipment royalty

Both

Same as in
case of royalty

France

Both

10%

Both

10%

Both

10%

Both

10%

Greece

Source

20%

Source

20%

Source

30%

No separate provision

Hungary

Both

10%

Both

10%

Both

10%

Both

10%

Indonesia

Both

10% if at least 25% of the shares of the company paying the dividend is held by the recipient; 15% in other cases

Both

10% [Note 2]

Both

15%

No separate provision

Ireland

Both

10%-15%

Both

10% [Note 2]

Both

10%

Both

10%

Israel

Both

10%

Both

10% [Note 2]

Both

10%

Both

10%

Italy

Both

15% if at least 10% of the shares of the company paying dividend is beneficially owned by the recipient company; 20% in other cases

Both

15% [Note 2]

Both

20%

Both

20%

Japan

Both

15%

Both

10% if the recipient of interest is bank; 15% for others [Note 2]

Both

20%

Both

20%

Jordan

Both

10%

Both

10% [Note 2]

Both

20%

Both

20%

Kazakstan

Both

10%

Both

10% [Note 2]

Both

10%

Both

10%

Kenya

Both

15%

Both

15% [Note 2]

Both

20%

Both

17.5%

Korea

Both

15% if at least 20% of the capital of the company paying dividend is held by the recipient; 20% in other cases

Both

10% if interest is paid to a bank; 15% for others [Note 2]

Both

15%

Both

15%

Kyrgyz Republic

Both

10%

Both

10%

Both

15%

Both

15%

Libyan Arab Jamahiriya

Source

20%

Source

20%

Source

30%

No provision

Malaysia

Both

10%

Both

10%

Both

10%

Both

10%

Malta

Both

10% if at least 25% of the shares of the company paying dividend is held by the recipient company; 15% in other cases

Both

10% [Note 2]

Both

15%

Both

10%

Mangolia

Both

15%

Both

15% [Note 2]

Both

15%

Both

25%

Mauritius

Both

5% if at least 10% of the capital of the company paying the dividend is held by the recipient; 15% in other cases

Both

20% [Note 2]

Both

15%

No separate provision

Morocco

Both

10%

Both

10% [Note 2]

Both

10%

Both

10%

Namibia

Both

10%

Both

10% [Note 2]

Both

10%

Both

10%

Nepal

Both

10% if at least 10% of the shares of the company paying the dividend is held by the recipient; 20% in other cases

Both

10% if interest is paid to bank 15% for others [Note 2]

Both

15%

No separate provision

Netherlands

Both

10%

Both

10% [Note 2]

Both

10-20%

Both

10-20%

New Zealand

Both

15%

Both

10% [Note 2]

Both

10%

Both

10%

Norway

Both

15% if at least 25% of the capital of the company paying the dividend is held by the recipient; 20% in other cases

Both

15% [Note 2]

Both

10%

Both

10%

Oman

Both

10% if at least 10% of shares are held by the recipient; 12.5% in other cases

Both

10% [Note 2]

Both

15%

Both

15%

Philippines

Both

15% if at least 10% of the shares of the company paying the dividend is held by the recipient; 20% in other cases

Both

10% if interest is received by a financial institution or insurance company; 15% in
other
cases

Both

15% if it is payable in pursuance
of any collab-
oration agreement approved
by the Govern-ment of India

Poland

Both

15%

Both

15% [Note 2]

Both

22.5%

Both

22.5%

Portuguese Republic

Both

10%

Both

10%

Both

10%

Both

10%

Quatar

Both

5%-10%

Both

10% [Note 2]

Both

10%

Both

10%

Romania

Both

15% if at least 25% of the shares of the company paying the dividend is held by the recipient; 20% in other cases

Both

15% [Note 2]

Both

22.5%

Both

22.5%

Russian Federation

Both

10%

Both

10% [Note 2]

Both

10%

Both

10%

Singapore

Both

10% if at least 25% of the shares of the company paying the dividend is held by the recipient; 15% in other cases

Both

10% if loan is granted
by a bank/
similar institute including an insurance company; 15% for others

Both

15% for copyrights; 10% for others

Both

15% for copyrights; 10% for others

South Africa

Both

10%

Both

10% [Note 2]

Both

10%

Spain

Both

15%

Both

15% [Note 2]

Both

[Note 4]

Both

10%

Srilanka

Both

15%

Both

10% [Note 2]

Both

10%

Both

[Note 4]

Sudan

Both

10%

Both

10%

Both

10%

Both

10%

Sweden

Both

10%

Both

10% [Note 2]

Both

10%

No separate provision

Swiss

Both

10%

Both

10% [Note 5]

Both

10%

Both

10%

Syria

Resid-ence

Nil

Both

7.5% [Note 2]

Both

10%

Both

10%

Tanzania

Both

10% if at least 10% of the shares of the company paying the dividend is held for a period of at least 6 months prior to the date of payment of the dividend; 15% in other cases

Both

12.5%

Both

20%

No separate provision

Thailand

Both

15% if dividend is paid by an industrial company and at least 10% of capital of such company is held by the recipient; 20% in other cases

Both

10% for financial institutions and insurance company; 20% for others [Note 2]

Both

15%

No separate provision

Trinidad and Tobago

Both

10%

Both

10% [Note 2]

Both

10%

Turkey

Both

15%

Both

10% if recipient is bank, etc.; 15% in
other cases [Note 2]

Both

15%

Both

15%

Turkmenistan

Both

10%

Both

10% [Note 2]

Both

10%

Uganda

Both

10%

Both

10%

Both

10%

Both

10%

Ukraine

Both

10%-15%

Both

10% [Note 2]

Both

10%

Both

10%

United Arab Emirates

Both

5% if at least 10% of the capital of the company paying dividend is held by the

Both

5% if loan
is granted
by a bank/
similar financial institute; 12.5% for others

Both

10%

Both

10%

recipient; 15% in other cases

No separate provision

United Arab Republic

Source

20%

Source

20%

Source

30%

No separate provision

United Kingdom

Both

15%

Both

10% if interest is paid to a bank; 15% for others [Note 2]

Both

[Note 3]

Both

[Note 3]

United States

Both

15% if at least 10% of the voting stock of the company paying the dividend is held by the recipient; 20% in other cases

Both

10% if loan is granted
by a bank/
similar institute including insurance company; 15% for others

Source

[Note 3]

Source

[Note 3]

Uzbekistan

Both

15%

Both

15% [Note 2]

Both

15%

Both

15%

Vietnam

Both

10%

Both

10% [Note 2]

Both

10%

Both

10%

Zambia

Both

5% if at least 25% of the shares of the company paying the dividend is held for a period of at least 6 months prior to the date of payment of the dividend; 15% in other cases

Both

10% [Note 2]

Both

10%

No separate provision