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Cross-border · DTAA

DTAA withholding tax — rates & calculator

For anyone receiving or paying into India from abroad — an NRI or a non-resident business. Find your country’s treaty rate on dividend, interest, royalty and technical fees, see it next to the domestic rate, and work out the tax.

When India pays dividend, interest, royalty or a technical-service fee to a non-resident, tax is withheld at source. A Double Taxation Avoidance Agreement (DTAA) often caps that rate below the domestic one — and under Section 159 (formerly Section 90) the non-resident applies the lower of the two.

Work out the rate & tax

Pick a country and income type — add an amount for the withholding.

Type of income
Treaty rate (DTAA)
Domestic rate (Act) 20%
You apply the lower

The lower of the treaty rate or the domestic rate applies under Section 159 (formerly Section 90), with a valid Tax Residency Certificate and Form 41 (formerly Form 10F). Surcharge and 4% cess apply only on the domestic rate, not the treaty rate.

All treaty rates, by country

95 countries · rates are the treaty (DTAA) withholding rates

95 countries

Country Dividend Interest Royalty FTS
Albania 10% 10% 10% 10%
Armenia 10% 10% 10% 10%
Australia No separate FTS article. 15% 15% 10% / 15%
Austria 10% 10% 10% 10%
Bangladesh Dividend 10% if recipient company holds ≥10% capital, else 15%. 10% / 15% 10% 10%
Belarus Dividend 10% if company holds 25% shares, else 15%. 10% / 15% 10% 15% 15%
Belgium Interest 10% if the loan is granted by a bank. 15% 15% 10% 10%
Bhutan 10% 10% 10% 10%
Botswana Dividend 7.5% if shareholder is a company holding ≥25% shares, else 10%. 7.5% / 10% 10% 10% 10%
Brazil Royalty 25% for trademark use, else 15%. (The two IT-portal tables differ on Brazil — confirm.) 15% 15% 25% / 15%
Bulgaria Royalty 15% for literary/artistic/scientific works (non-film), else 20%. 15% 15% 15% / 20% 20%
Canada Dividend 15% if recipient company controls ≥10% voting power, else 25%. 15% / 25% 15% 10–20% 10–20%
China 10% 10% 10% 10%
Colombia 5% 10% 10% 10%
Croatia Dividend 5% if company holds ≥10% capital, else 15%. 5% / 15% 10% 10% 10%
Cyprus 10% 10% 10% 10%
Czech Republic 10% 10% 10% 10%
Denmark Dividend 15% if company holds ≥25% shares, else 25%. Interest 10% if loan by a bank, else 15%. 15% / 25% 10% / 15% 20% 20%
Estonia 10% 10% 10% 10%
Ethiopia 7.5% 10% 10% 10%
Finland 10% 10% 10% 10%
Fiji 5% 10% 10% 10%
France 10% 10% 10% 10%
Georgia 10% 10% 10% 10%
Germany 10% 10% 10% 10%
Greece Older treaty — domestic-rate-linked for some heads. 20% 20% 10%
Hong Kong 5% 10% 10% 10%
Hungary 10% 10% 10% 10%
Indonesia 10% 10% 10% 10%
Iceland 10% 10% 10% 10%
Ireland 10% 10% 10% 10%
Iran 10% 10% 10% 10%
Israel 10% 10% 10% 10%
Italy Dividend 15% if company beneficially owns ≥10% shares, else 25%. 15% / 25% 15% 20% 20%
Japan 10% 10% 10% 10%
Jordan Royalty/FTS 20% per the table — some sources cite 10%; confirm. 10% 10% 20% 20%
Kazakhstan 10% 10% 10% 10%
Kenya 10% 10% 10% 10%
Korea 15% 10% 10% 10%
Kuwait 10% 10% 10% 10%
Kyrgyz Republic 10% 10% 15% 15%
Libya Older treaty — confirm dividend rate. 10% 20% 20%
Latvia 10% 10% 10% 10%
Lithuania Dividend 5% if a non-partnership company holds ≥10% capital, else 15%. 5% / 15% 10% 10% 10%
Luxembourg 10% 10% 10% 10%
Malaysia 5% 10% 10% 10%
Malta 10% 10% 10% 10%
Mongolia 15% 15% 15% 15%
Mauritius Dividend 5% if company holds ≥10% capital, else 15%. 5% / 15% 7.5% 15% 10%
Montenegro Dividend 5% if a non-partnership company holds ≥25% capital, else 15%. 5% / 15% 10% 10% 10%
Myanmar 5% 10% 10%
Morocco 10% 10% 10% 10%
Mozambique 7.5% 10% 10%
Macedonia 10% 10% 10% 10%
Namibia 10% 10% 10% 10%
Nepal Dividend 5% if company owns ≥10% shares, else 10% (per treaty — confirm). 5% / 10% 10% 15%
Netherlands 10% 10% 10% 10%
New Zealand 15% 10% 10% 10%
Norway 10% 10% 10% 10%
Oman Dividend 10% if recipient company holds ≥10% shares, else 12.5%. 10% / 12.5% 10% 15% 15%
Philippines Dividend 15% if company holds ≥10% shares, else 20%. Interest 10% if received by a financial institution/insurer, else 15%. Royalty 15% if under a Govt-approved collaboration agreement. 15% / 20% 10% / 15% 15%
Poland Royalty/FTS 22.5% per the table — the 2014 protocol generally applies 15%; confirm. 10% 10% 22.5% 22.5%
Portuguese Republic 10% / 15% 10% 10% 10%
Qatar Dividend 5% if company owns ≥10% shares, else 10%. 5% / 10% 10% 10% 10%
Romania 10% 10% 10% 10%
Russian Federation 10% 10% 10% 10%
Saudi Arabia 5% 10% 10%
Serbia Dividend 5% if recipient is a company holding 25% shares, else 15%. 5% / 15% 10% 10% 10%
Singapore Dividend 10% if company holds ≥25% shares, else 15%. Interest 10% if loan by a bank/financial institution, else 15%. 10% / 15% 10% / 15% 10% 10%
Slovenia Dividend 5% if company owns ≥10% shares, else 15%. 5% / 15% 10% 10% 10%
South Africa 10% 10% 10% 10%
Spain 15% 15% 10% 10%
Sri Lanka 7.5% 10% 10% 10%
Sudan 10% 10% 10% 10%
Sweden 10% 10% 10% 10%
Switzerland 10% 10% 10% 10%
Syrian Arab Republic Dividend 5% if company holds ≥10% shares, else 10%. 5% / 10% 10% 10%
Taipei (Taiwan) 12.5% 10% 10% 10%
Tajikistan Dividend 5% if company holds ≥25% shares, else 10%. 5% / 10% 10% 10%
Tanzania Dividend 5% if shareholder is a company holding 25% shares, else 10%. 5% / 10% 10% 10%
Thailand 10% 10% 10%
Trinidad and Tobago 10% 10% 10% 10%
Turkey Interest 10% if loan by a bank, etc., else 15%. 15% 10% / 15% 15% 15%
Turkmenistan 10% 10% 10% 10%
Uganda 10% 10% 10% 10%
Ukraine Dividend 10% if company holds ≥25% shares, else 15%. 10% / 15% 10% 10% 10%
United Arab Emirates (UAE) Interest 5% if loan by a bank/similar financial institution, else 12.5%. 10% 5% / 12.5% 10%
United Arab Republic (Egypt) The India–Egypt treaty has no withholding articles for dividend/interest/royalty — tax is withheld at the Income-tax Act rate. 10% / 20% 20% 20%
United Mexican States 10% 10% 10% 10%
United Kingdom Dividend 15% where paid out of income from immovable property by an investment vehicle, else 10%. Interest 10% if paid to a bank, else 15%. 10% / 15% 10% / 15% 10% / 15% 10% / 15%
United States Dividend 15% if company holds ≥10% voting stock, else 25%. Interest 10% if loan by a bank/financial institution/insurer, else 15%. 15% / 25% 10% / 15% 10% / 15% 10% / 15%
Uruguay 5% 10% 10% 10%
Uzbekistan 10% 10% 10% 10%
Vietnam 10% 10% 10% 10%
Zambia Dividend 5% if company has held ≥25% shares for ≥6 months before payment, else 15%. 5% / 15% 10% 10% 10%

“FTS” = fees for technical services. “—” = no separate treaty article, so the Income-tax Act rate applies. A rate like “10% / 15%” is conditional — see the note. Apply the lower of the treaty rate or the domestic Act rate (dividend 20%, interest 20% / 5%, royalty 20%, FTS 20% — plus surcharge and 4% cess on the domestic rate only), with a valid TRC.

How a non-resident gets the treaty rate

TRC + Form 41

A Tax Residency Certificate from the home country, plus Form 41 (formerly Form 10F), are needed to claim the treaty rate.

Beneficial ownership

Beneficial ownership of the income — and, for many treaties, a holding threshold — must be satisfied for the lower rate.

No surcharge on treaty rate

No surcharge or cess is added on the treaty rate; those apply only on the domestic Income-tax Act rate.

Anti-abuse rules still apply

The MLI / principal-purpose test and GAAR can still deny a treaty benefit in the wrong fact pattern.

Common questions

Treaty rate or Income-tax Act rate — which applies?

Under Section 159 (formerly Section 90), apply whichever is lower — the DTAA rate or the domestic Act rate — with a valid TRC and Form 41, and subject to beneficial ownership and other treaty conditions.

Is surcharge and cess added on top of the DTAA rate?

No. Surcharge and the 4% health & education cess apply on the domestic Income-tax Act rate, not on the treaty rate. Where the treaty rate applies, it is the final withholding rate.

What is the DTAA rate on dividends from India to the USA?

Under the India–US treaty it is 15% if the recipient company holds at least 10% of the voting stock, otherwise 25% — then apply the lower of this or the 20% domestic rate, with a valid TRC.

What is the DTAA rate on royalty and fees for technical services?

In most of India’s treaties it is 10%, though several countries are higher (for example 15% or 20%). Use the calculator or search the country in the table.

Do DTAA rates change every financial year?

No. Treaty rates change only when the treaty or a protocol is renegotiated. The domestic comparison rate is the current-year Income-tax Act rate (Tax Year 2026-27, Section 393(2) of the Income-tax Act, 2025).

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