Withholding rate of tax in respect of dividend - We are not ...

Case Laws Income Tax

April 26, 2021

Withholding rate of tax in respect of dividend - We are not impressed with the argument advanced on behalf of the revenue that since Slovenia, Lithuania, and Columbia became members of the OECD, not only after the subject DTAA came into force but also after their own DTAA came into force, and therefore, lower rate of withholding tax, i.e., 5% on dividends would not apply to recipients in the Netherlands, who are otherwise covered under the subject DTAA - as that is not how the other contracting State, i.e., the Netherlands has interpreted Clause IV (2) of the protocol appended to the subject DTAA. - HC

View Source

← Previous Next →

Withholding rate of tax in respect of dividend - We are not ...

Case Laws Income Tax

April 26, 2021

You may also like:

Rate of tax payable on Dividend Distribution Tax (DDT) - Distribution of dividends to its share holders (Germany) (Non-residents) - the additional income tax payable by...

Writ petitions challenged the 4% withholding tax rate u/s 195 on receipts asserted as business income u/s 9(1)(i), despite the petitioner having withheld tax at 1.5%....

Orders/certificates u/s 197 - rate of withholding tax - he petitioner, who is a non-resident and does not have a PE in India, claims that the subject income is “business...

Refund of excess Dividend Distribution Tax - additional income tax payable by the domestic company shall be at the rate mentioned in section 115-O of the Act and not at...

Application u/s 197 - reduction of withholding tax - petitioner had sought a certificate, at “NIL” rate of tax - request to issue certificate at lower was rejected -...

Taxability of dividends - dividend is declared, distributed or paid by a domestic company to a non-resident shareholder(s) - The Tribunal held that, additional income...

Deemed Dividend - addition of advance salary as deemed dividend - advance was not in the nature of loan and hence cannot be treated as deemed dividend u/s 2(22)(e) - AT

The assessee claimed deduction of expenditure incurred for handling and disposal of spent solvents/scrap against unaccounted cash receipts from their sale. The ITAT held...

Sections 132B, 140A, 153A and 234B of the Income Tax Act, 1961 were analyzed regarding adjustment of seized cash against tax liability. The appellants claimed that cash...

Assessee company paid Dividend Distribution Tax (DDT) on dividends distributed to its holding company, a tax resident of Mauritius, at higher rates under the Income Tax...

Interest u/s. 234C - advance tax - dividend has been received by the assessee only in third and fourth quarters of the financial year - the assessee had duly paid the...

Deemed dividend u/s 2(22)(e) - assessee is a major share holder in loan granting company - Advance given for purchase of property - The words “loans or advances”...

Reforms in Tax Rates - tax rates of the major countries of Asia

Interest u/s 234C - interest for deferment of advance tax - If on a particular due date for payment of advance tax, the facts show that there is no liability to pay...

Deemed dividend u/s 2(22))e) - repayment of loan or advance by the Company

Quick Updates: