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Tax-Treaty-Withholding-Rates.txt
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Tax-Treaty-Withholding-Rates.txt
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Tax Treaty
Withholding
Rates
India > Singapore
Payor Payee Type of General Additional Information on the Payment CCH Links
Payment Tax
Rate
India SingaporeDividend 0.15 World
Treaties¶3743.01(A)Art10
• The rate is 10 per cent of the gross amount of the
dividends if the beneficial owner is a company which owns at
last 25 per cent of the shares of the company paying the
dividends.
• Non-treaty general withholding rate percentages are:
Dividends--20 (+ surcharges); Interest--20 (+ surcharges);
Royalties--10 (+ surcharges).
India SingaporeInterest 0.15 World
Treaties¶3743.01(A)Art11
• The rate is 10 per cent of the gross amount of the interest
if such interest is paid on a loan granted by a bank carrying on
a bona fide banking business or by a similar financial
institution (including an insurance company); 15 per cent of
the gross amount of the interest in all other cases.
• Non-treaty general withholding rate percentages are:
Dividends--20 (+ surcharges); Interest--20 (+ surcharges);
Royalties--10 (+ surcharges).
India SingaporeRoyalties 0.1 World
Treaties¶3743.01(A)Art12
• Non-treaty general withholding rate percentages are:
Dividends--20 (+ surcharges); Interest--20 (+ surcharges);
Royalties--10 (+ surcharges).
India SingaporeTechnical 0.1 World
Services Treaties¶3743.01(A)Art12
India > United Kingdom
Payor Payee Type of General Additional Information on the Payment CCH Links
Payment Tax
Rate
India United Dividend 0.1 World
Kingdom Treaties¶3756.01(A)Art11
• The rate is 15 percent of the gross amount of the dividends
where those dividends are paid out of income (including
gains) derived directly or indirectly from immovable property
within the meaning of Article 6 by an investment vehicle which
distributes most of this income annually and whose income
from such immovable property is exempted from tax; 10
percent of the gross amount of the dividends, in all other
cases.
• Non-treaty general withholding rate percentages are:
Dividends--20 (+ surcharges); Interest--20 (+ surcharges);
Royalties--10 (+ surcharges).
India United Interest 0.2 World
Kingdom Treaties¶3756.01(A)Art12
• Non-treaty general withholding rate percentages are:
Dividends--20 (+ surcharges); Interest--20 (+ surcharges);
Royalties--10 (+ surcharges).
India United Royalties 0.2 World
Kingdom Treaties¶3756.01(A)Art13
• Royalties and fees for technical services may also be taxed
in the Contracting State in which they arise and according to
the law of that State; but if the beneficial owner of the
royalties or fees for technical services is a resident of the
other Contracting State, the tax so charged shall not exceed:
(a) in the case of royalties within paragraph (3)(a) of this
Article, and fees for technical services within paragraph (4)(a)
and (c) of this Article; (i) during the first five years for which
this Convention has effect; (aa) 15 per cent of the gross
amount of such royalties or fees for technical services when
the payer of the royalties or fees for technical services is the
Government of the first-mentioned Contracting State or a
political subdivision of that State, and (bb) 20 per cent of the
gross amount of such royalties or fees for technical services
in all other cases; and(ii) during subsequent years, 15 per
cent of the gross amount of such royalties or fees for
technical services;and (b) in the case of royalties within
paragraph (3)(b) of this Article and fees for technical services
defined in paragraph (4)(b) of this Article, 10 per cent of the
gross amount of such royalties and fees for technical
services.
• Non-treaty general withholding rate percentages are:
Dividends--20 (+ surcharges); Interest--20 (+ surcharges);
Royalties--10 (+ surcharges).
India United Technical 0.2 World
Kingdom Services Treaties¶3756.01(A)Art13
India > USA
Payor Payee Type of General Additional Information on the Payment CCH Links
Payment Tax
Rate
India USA Dividend 0.25 World
Treaties¶3758.01Art10
• The rate is 15 per cent of the gross amount of the
dividends if the beneficial owner is a company which owns at
least 10 per cent of the voting stock of the company paying
the dividends; 25 per cent of the gross amount of the
dividends in all other cases.
• Non-treaty general withholding rate percentages are:
Dividends--20 (+ surcharges); Interest--20 (+ surcharges);
Royalties--10 (+ surcharges).
India USA Interest 0.15 World
Treaties¶3758.01Art11
• The rate is 10 per cent of the gross amount of the interest
if such interest is paid on a loan granted by a bank carrying on
a bona fide banking business or by a similar financial
institution (including an insurance company); and 15 per cent
of the gross amount of the interest in all other cases.
However, interest is exempt if derived and beneficially owned
by the Government, a political subdivision or local authority,
the Reserve Bank of India, or the Federal Reserve Banks of
the United States, as the case may be, and such other
institutions of either Contracting State as the competent
authorities may agree pursuant to Article 27 (Mutual
Agreement Procedure); and with respect to certain endorsed
loans or credits extended.
• Non-treaty general withholding rate percentages are:
Dividends--20 (+ surcharges); Interest--20 (+ surcharges);
Royalties--10 (+ surcharges).
India USA Royalties 0.1 World
Treaties¶3758.01Art12
• The non-treaty rate for royalties and technical services is
10 percent and as it is lower than the treaty rate, it should be
used as the withholding rate.
• In the case of royalties for payments of any kind received
as a consideration for the use of, or the right to use, any
copyright of a literary, artistic, or scientific work, including
cinematograph films or work on film, tape or other means of
reproduction for use in connection with radio or television
broadcasting, any patent, trademark, design or model, plan,
secret formula or process, or for information concerning
industrial, commercial or scientific experience, including gains
derived from the alienation of any such right or property which
are contingent on the productivity, use, or disposition thereof;
and fees for included services during the first five taxable
years for which this Convention has effect, (A) 15 per cent of
the gross amount of the royalties or fees for included services
as defined in this Article, where the payer of the royalties or
fees is the Government of that Contracting State, a political
subdivision or a public sector company; and (B) 20 per cent of
the gross amount of the royalties or fees for included services
in all other cases; and (ii) during the subsequent years, 15 per
cent of the gross amount of royalties or fees for included
services. In the case of royalties for payments of any kind
received as consideration for the use of, or the right to use,
any industrial, commercial, or scientific equipment (with some
exceptions), and fees for included services that are ancillary
and subsidiary to the enjoyment of the property for which
payment is received, 10 per cent of the gross amount of the
royalties or fees for included services.
• Non-treaty general withholding rate percentages are:
Dividends--20 (+ surcharges); Interest--20 (+ surcharges);
Royalties--10 (+ surcharges).
India USA Technical 0.1 World
Services Treaties¶3758.01Art12
• The non-treaty rate for royalties and technical services is
10 percent and as it is lower than the treaty rate, it should be
used as the withholding rate.
• In the case of royalties for payments of any kind received
as a consideration for the use of, or the right to use, any
copyright of a literary, artistic, or scientific work, including
cinematograph films or work on film, tape or other means of
reproduction for use in connection with radio or television
broadcasting, any patent, trademark, design or model, plan,
secret formula or process, or for information concerning
industrial, commercial or scientific experience, including gains
derived from the alienation of any such right or property which
are contingent on the productivity, use, or disposition thereof;
and fees for included services during the first five taxable
years for which this Convention has effect, (A) 15 per cent of
the gross amount of the royalties or fees for included services
as defined in this Article, where the payer of the royalties or
fees is the Government of that Contracting State, a political
subdivision or a public sector company; and (B) 20 per cent of
the gross amount of the royalties or fees for included services
in all other cases; and (ii) during the subsequent years, 15 per
cent of the gross amount of royalties or fees for included
services. In the case of royalties for payments of any kind
received as consideration for the use of, or the right to use,
any industrial, commercial, or scientific equipment (with some
exceptions), and fees for included services that are ancillary
and subsidiary to the enjoyment of the property for which
payment is received, 10 per cent of the gross amount of the
royalties or fees for included services.
Singapore > India
Payor Payee Type of General Additional Information on the Payment CCH Links
Payment Tax
Rate
Singapore India Dividend 0.15 World
Treaties¶3743.01(A)Art10
• The rate is 10 per cent of the gross amount of the
dividends if the beneficial owner is a company which owns at
last 25 per cent of the shares of the company paying the
dividends; 15 per cent of the gross amount of the dividends in
all other cases.
• Nontreaty general withholding rate percentages are:
Dividends--0; Interest--15; Royalties--10.
Singapore India Interest 0.15 World
Treaties¶3743.01(A)Art11
• The rate is 10 per cent of the gross amount of the interest
if such interest is paid on a loan granted by a bank carrying on
a bona fide banking business or by a similar financial
institution (including an insurance company); 15 per cent of
the gross amount of the interest in all other cases.
• Nontreaty general withholding rate percentages are:
Dividends--0; Interest--15; Royalties--10.
Singapore India Royalties 0.1 World
Treaties¶3743.01(A)Art12
• Nontreaty general withholding rate percentages are:
Dividends--0; Interest--15; Royalties--10.
Singapore India Technical 0.1 World
Services Treaties¶3743.01(A)Art12
Singapore > United Kingdom
Payor Payee Type of General Additional Information on the Payment CCH Links
Payment Tax
Rate
Singapore United Dividend 0 World
Kingdom Treaties¶4264.01(A)Art10
• The rate is 15 percent for real estate investment trust
distributions.
• Nontreaty general withholding rate percentages are:
Dividends--0; Interest--15; Royalties--10.
Singapore United Interest 0.05 World
Kingdom Treaties¶4264.01(A)Art11
• Nontreaty general withholding rate percentages are:
Dividends--0; Interest--15; Royalties--10.
Singapore United Royalties 0.08 World
Kingdom Treaties¶4264.01(A)Art12
• Nontreaty general withholding rate percentages are:
Dividends--0; Interest--15; Royalties--10.
Singapore United Technical 0.17 World
Kingdom Services Treaties¶4264.01(A)
• The treaty does not explicitly reference a withholding rate
for technical services. Therefore, unless another treaty
provision applies (e.g., royalties, independent personal
services, business profits, etc.), domestic law controls. The
withholding tax rate in Singapore for other items with non-
treaty countries is generally 15%. For technical and other
service fees paid to a non-resident company, the withholding
tax rate is 17%. Technical service fees paid to non-resident
individuals are subject to withholding tax at 20%. Therefore,
the general domestic law withholding rate for Singapore-
sourced fees paid to non-residents for technical services is
17% (or 20% if paid to individuals).
United Kingdom > India
Payor Payee Type of General Additional Information on the Payment CCH Links
Payment Tax
Rate
United KingdomIndia Dividend 0 World
Treaties¶3756.01(A)Art11
• The UK generally does not have a withholding tax on
dividends paid to a UK resident or non-resident company
unless the dividends are paid by a real estate investment
trust.
• The treaty provides that the rate is 15 percent of the gross
amount of the dividends where those dividends are paid out
of income (including gains) derived directly or indirectly from
immovable property within the meaning of Article 6 by an
investment vehicle which distributes most of this income
annually and whose income from such immovable property is
exempted from tax; 10 percent of the gross amount of the
dividends, in all other cases.
• Non-treaty general withholding rate percentages are:
Dividends--0; Interest--20; Royalties--20.
United KingdomIndia Interest 0.15 World
Treaties¶3756.01(A)Art12
• Non-treaty general withholding rate percentages are:
Dividends--0; Interest--20; Royalties--20.
United KingdomIndia Royalties 0.2 World
Treaties¶3756.01(A)Art13
• Royalties and fees for technical services may also be taxed
in the Contracting State in which they arise and according to
the law of that State; but if the beneficial owner of the
royalties or fees for technical services is a resident of the
other Contracting State, the tax so charged shall not exceed:
(a) in the case of royalties within paragraph (3)(a) of this
Article, and fees for technical services within paragraph (4)(a)
and (c) of this Article; (i) during the first five years for which
this Convention has effect; (aa) 15 per cent of the gross
amount of such royalties or fees for technical services when
the payer of the royalties or fees for technical services is the
Government of the first-mentioned Contracting State or a
political subdivision of that State, and (bb) 20 per cent of the
gross amount of such royalties or fees for technical services
in all other cases; and(ii) during subsequent years, 15 per
cent of the gross amount of such royalties or fees for
technical services;and (b) in the case of royalties within
paragraph (3)(b) of this Article and fees for technical services
defined in paragraph (4)(b) of this Article, 10 per cent of the
gross amount of such royalties and fees for technical
services.
• In general, unless a reduced treaty rate applies, under
domestic law UK source patent, copyright, design, model,
plan, secret formula, trademark, brand names and know-how
royalty payments are subject to a 20 percent withholding tax.
Film related royalty payments are generally exempt from
withholding tax.
• Non-treaty general withholding rate percentages are:
Dividends--0; Interest--20; Royalties--20.
United KingdomIndia Technical 0.2 World
Services Treaties¶3756.01(A)Art13
United Kingdom > Singapore
Payor Payee Type of General Additional Information on the Payment CCH Links
Payment Tax
Rate
United KingdomSingaporeDividend 0 World
Treaties¶4264.01(A)Art10
• The UK generally does not have a withholding tax on
dividends paid to a UK resident or non-resident company
unless the dividends are paid by a real estate investment
trust.
• Real estate investment trust distributions are subject to a
15 per cent rate.
• Non-treaty general withholding rate percentages are:
Dividends--0; Interest--20; Royalties--20.
United KingdomSingaporeInterest 0.05 World
Treaties¶4264.01(A)Art11
• Non-treaty general withholding rate percentages are:
Dividends--0; Interest--20; Royalties--20.
United KingdomSingaporeRoyalties 0.08 World
Treaties¶4264.01(A)Art12
• In general, unless a reduced treaty rate applies, under
domestic law UK source patent, copyright, design, model,
plan, secret formula, trademark, brand names and know-how
royalty payments are subject to a 20 percent withholding tax.
Film related royalty payments are generally exempt from
withholding tax.
• Non-treaty general withholding rate percentages are:
Dividends--0; Interest--20; Royalties--20.
United KingdomSingaporeTechnical 0 World
Services Treaties¶4264.01(A)
• The treaty does not explicitly reference a withholding rate
for technical services. Therefore, unless another treaty
provision applies (e.g., royalties, independent personal
services, business profits, etc.), domestic law controls. The
general domestic default withholding rate for UK-sourced
payments to nonresidents is 0%.
United Kingdom > USA
Payor Payee Type of General Additional Information on the Payment CCH Links
Payment Tax
Rate
United KingdomUSA Dividend 0 World
Treaties¶4332.01(A)Art10
• The UK generally does not have a withholding tax on
dividends paid to a UK resident or non-resident company
unless the dividends are paid by a real estate investment
trust.
• The treaty provides for a rate of 5 per cent of the gross
amount of the dividends if the beneficial owner is a company
that owns shares representing directly or indirectly at least 10
per cent of the voting power of the company paying the
dividends; 15 per cent of the gross amount of the dividends in
all other cases.
• Non-treaty general withholding rate percentages are:
Dividends--0; Interest--20; Royalties--20.
United KingdomUSA Interest 0 World
Treaties¶4332.01(A)Art11
• Non-treaty general withholding rate percentages are:
Dividends--0; Interest--20; Royalties--20.
United KingdomUSA Royalties 0 World
Treaties¶4332.01(A)Art12
• In general, unless a reduced treaty rate applies, under
domestic law UK source patent, copyright, design, model,
plan, secret formula, trademark, brand names and know-how
royalty payments are subject to a 20 percent withholding tax.
Film related royalty payments are generally exempt from
withholding tax.
• Non-treaty general withholding rate percentages are:
Dividends--0; Interest--20; Royalties--20.
United KingdomUSA Technical 0 World
Services Treaties¶4332.01(A)
• The treaty does not explicitly reference a withholding rate
for technical services. Therefore, unless another treaty
provision applies (e.g., royalties, independent personal
services, business profits, etc.), domestic law controls. The
general domestic default withholding rate for UK-sourced
payments to nonresidents is 0%.
USA > India
Payor Payee Type of General Additional Information on the Payment CCH Links
Payment Tax
Rate
USA India Dividend 0.25 World
Treaties¶3758.01Art10
• A rate of 15 percent of the gross amount of the dividends
applies if the beneficial owner is a company which owns at
least 10 per cent of the voting stock of the company paying
the dividends; 25 percent of the gross amount of the
dividends in all other cases.
• Non-treaty general withholding rate percentages are:
Dividends--30; Interest--30; Royalties--30.
USA India Interest 0.15 World
Treaties¶3758.01Art11
• A rate of 10 percent of the gross amount of the interest
applies if such interest is paid on a loan granted by a bank
carrying on a bona fide banking business or by a similar
financial institution (including an insurance company); and 15
percent of the gross amount of the interest in all other cases.
• Non-treaty general withholding rate percentages are:
Dividends--30; Interest--30; Royalties--30.
USA India Royalties 0.15 World
Treaties¶3758.01Art12
• In the case of royalties for payments of any kind received
as a consideration for the use of, or the right to use, any
copyright of a literary, artistic, or scientific work, including
cinematograph films or work on film, tape or other means of
reproduction for use in connection with radio or television
broadcasting, any patent, trademark, design or model, plan,
secret formula or process, or for information concerning
industrial, commercial or scientific experience, including gains
derived from the alienation of any such right or property which
are contingent on the productivity, use, or disposition thereof;
and fees for included services during the first five taxable
years for which this Convention has effect, (A) 15 per cent of
the gross amount of the royalties or fees for included services
as defined in this Article, where the payer of the royalties or
fees is the Government of that Contracting State, a political
subdivision or a public sector company; and (B) 20 per cent of
the gross amount of the royalties or fees for included services
in all other cases; and (ii) during the subsequent years, 15 per
cent of the gross amount of royalties or fees for included
services. In the case of royalties for payments of any kind
received as consideration for the use of, or the right to use,
any industrial, commercial, or scientific equipment (with some
exceptions), and fees for included services that are ancillary
and subsidiary to the enjoyment of the property for which
payment is received, 10 per cent of the gross amount of the
royalties or fees for included services.
• Non-treaty general withholding rate percentages are:
Dividends--30; Interest--30; Royalties--30.
USA India Technical 0.15 World
Services Treaties¶3758.01Art12
• In the case of royalties for payments of any kind received
as a consideration for the use of, or the right to use, any
copyright of a literary, artistic, or scientific work, including
cinematograph films or work on film, tape or other means of
reproduction for use in connection with radio or television
broadcasting, any patent, trademark, design or model, plan,
secret formula or process, or for information concerning
industrial, commercial or scientific experience, including gains
derived from the alienation of any such right or property which
are contingent on the productivity, use, or disposition thereof;
and fees for included services during the first five taxable
years for which this Convention has effect, (A) 15 per cent of
the gross amount of the royalties or fees for included services
as defined in this Article, where the payer of the royalties or
fees is the Government of that Contracting State, a political
subdivision or a public sector company; and (B) 20 per cent of
the gross amount of the royalties or fees for included services
in all other cases; and (ii) during the subsequent years, 15 per
cent of the gross amount of royalties or fees for included
services. In the case of royalties for payments of any kind
received as consideration for the use of, or the right to use,
any industrial, commercial, or scientific equipment (with some
exceptions), and fees for included services that are ancillary
and subsidiary to the enjoyment of the property for which
payment is received, 10 per cent of the gross amount of the
royalties or fees for included services.
USA > United Kingdom
Payor Payee Type of General Additional Information on the Payment CCH Links
Payment Tax
Rate
USA United Dividend 0.15 World
Kingdom Treaties¶4332.01(A)Art10
• The rate is 5 per cent. of the gross amount of the dividends
if the beneficial owner is a company that owns shares
representing directly or indirectly at least 10 per cent. of the
voting power of the company paying the dividends;15 per
cent. of the gross amount of the dividends in all other cases.
However, dividends shall not be taxed in the Contracting
State of which the company paying the dividends is a resident
if the beneficial owner of the dividends is a resident of the
other Contracting State and either: (a) a company that has
owned shares representing 80 per cent or more of the voting
power of the company paying the dividends for a 12-month
period ending on the date the dividend is declared, and that:
(i) owned shares representing, directly or indirectly, at least
80 per cent. of the voting power of the company paying the
dividends prior to October 1st, 1998; or (ii) is a qualified
person by reason of certain limitations on benefits provisions;
or (b) a pension scheme, provided that such dividends are not
derived from the carrying on of a business, directly or
indirectly, by such pension scheme.
• Nontreaty general withholding rate percentages are:
Dividends—30; Interest—30; Royalties—30.
USA United Interest 0 World
Kingdom Treaties¶4332.01(A)Art11
• Nontreaty general withholding rate percentages are:
Dividends--30; Interest--30; Royalties--30.
USA United Royalties 0 World
Kingdom Treaties¶4332.01(A)Art12
• Nontreaty general withholding rate percentages are:
Dividends--30; Interest--30; Royalties--30.
USA United Technical 0.3 World
Kingdom Services Treaties¶4332.01(A)
• The treaty does not explicitly reference a withholding rate
for technical services. Therefore, unless another treaty
provision applies (e.g., royalties, independent personal
services, business profits, etc.), domestic law controls. The
withholding tax rate on payments made to foreign companies
is generally 30% unless a reduced treaty rate applies or the
income is classified as effectively connected income where it
would be taxed at a rate of 21% (for corporations).
Date Prepared: 5/27/2024 3:49:14 PM (UTC+5:30)
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