DTAA Tax Rate Finder
Country-Wise
Dividend · Interest · Royalty · FTS — All 90+ Countries

Step 1: Identify the country of residence of the recipient and the type of income (dividend, interest, royalty, FTS). Step 2: Look up the DTAA rate using this finder. Step 3: Obtain the Tax Residency Certificate (TRC) from the recipient (they get it from their home country's tax authority). Step 4: The recipient files Form 10F/Form 41 on incometax.gov.in. Step 5: The recipient provides a self-declaration of beneficial ownership and no-PE status. Step 6: Your CA issues Form 15CB certifying the DTAA rate is applicable and correctly computed. Step 7: You file Form 15CA on the income tax portal. Step 8: Submit Form 15CA/15CB to your AD bank. The bank will deduct TDS at the DTAA rate and remit the net amount abroad. TAXAJ handles the complete 15CA/15CB process with DTAA advisory.

Under the India-USA DTAA, royalties are taxed at 15%. However, the "Make Available" clause in the India-USA treaty means that FTS (fees for technical services) is taxed at 15% only if the services "make available" technology. If the services do not make available technology, they may be classified as business profits — taxable only if the US company has a PE (Permanent Establishment) in India. Without PE, no tax in India. This distinction is crucial for software development services, consulting fees, and professional service payments. The domestic rate would be 20% — so the treaty saves 5%. Form 15CB + 15CA required, plus TRC from the US company.

Historically, Mauritius (0% capital gains) and Singapore (0% capital gains before 2017 amendment) had the most favorable DTAAs with India — particularly on capital gains tax. However, both treaties were amended in 2016 (Mauritius) and 2017 (Singapore): capital gains on shares acquired after April 1, 2017 are now taxable in India at standard rates (10% LTCG, 15% STCG on listed shares). The grandfathering clause protects investments made before those dates. Post-amendment, Mauritius still offers 5%/15% dividend rates and 7.5%/10% capital gains on listed shares (reducing tax). The MLI's Principal Purpose Test (PPT) now allows India to scrutinize whether treaty benefits are being sought as the principal purpose — treaty shopping is increasingly risky without genuine commercial substance in the holding company's country.

Under the India-UAE DTAA, dividend withholding tax is at a maximum of 10% (for companies holding at least 10% equity) or 5% (for specific categories). The domestic rate would be 20%. This makes UAE a popular holding jurisdiction for Indian subsidiaries — particularly for Middle East businesses with genuine operations in UAE. Bank interest under India-UAE DTAA attracts only 5% (for bank/financial institution loans), one of the lowest in India's treaty network. FTS is not specifically covered in India-UAE DTAA — so FTS payments may be taxed as business profits (0% if no PE) or at the domestic rate depending on interpretation. TRC from UAE authority + Form 10F required.

Under Section 90(2) of the Income Tax Act, a taxpayer can apply whichever is more beneficial — the DTAA rate or the IT Act rate. Since DTAA rates are almost always lower than domestic rates, DTAA rates generally apply. However, GAAR (General Anti-Avoidance Rules) under Chapter X-A of the IT Act can override DTAA benefits if an arrangement is found to be an "impermissible avoidance arrangement." The MLI's Principal Purpose Test (PPT) operates similarly. In practice: present both rates to your CA, confirm the beneficial rate, obtain TRC + Form 10F, and proceed with 15CB at the DTAA rate. Note: Income Tax India publishes the DTAA vis-à-vis IT Act comparison table at incometaxindia.gov.in for reference.