Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding


  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights April 2021 Year 2021 This

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

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

 


 

You may also like:

  1. 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...

  2. 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

  3. Deemed dividend u/s 2(22)(e) - oan or advance to a non-shareholder cannot be taxed as deemed dividend in the hands of the a non shareholder - AT

  4. 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...

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

  6. Deemed dividend - looking at the transactions from the objects of section 2(22)(e) it cannot be said that there was diversion of dividend in the form of loans or advances.

  7. Deemed dividend - looking at the transactions from the objects of section 2(22)(e) it cannot be said that there was diversion of dividend in the form of loans or advances.

  8. Deemed dividend addition u/s.2(22) - trade advance in relation to business transaction cannot be treated as deemed dividend - AT

  9. Deemed dividend u/s 2(22)(e) - payments made by the company towards advances to the assessee fulfils all the characteristics of 'dividend' as envisaged in S. 2(22)(e) - AT

  10. Deemed Dividends - Advance from Company - for applicability of deemed dividends accumulated profits should exist on the date of loan - AT

 

Quick Updates:Latest Updates