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Annexure 2

Tax Rates Applicable as per Treaties that India has entered into with various countries

Country

Date of Treaty

Tax on Dividend
(Rate in %)

Tax on Interest
(Rate in %)

Tax on Royalty
(Rate in %)

Tax on Technical service fee
(Rate in %)

Remarks

AUSTRALIA

25.7.1991

15

15

First five years of effect of agreement

15

20

15

20

15% on royalties if payer is government or specified organisation; 20% in other cases
Subsequent years  
15 15 Whether payer is government or others
10 10 10% in respect of use of or right to use of equipment and services connected therewith.
AUSTRIA 08.11.1999 10 10 10 10  

CANADA

11.1.1996

15

25

15

 

15 on dividend
where beneficial owner is Company owing at least 10% of costing stock 25% in other cases

First five years of effect of agreement
15

20

15

20

15% on royalties if
payer is government etc; 20% in other cases
Subsequent years
15 15 In any case
10 10 10% in respect of use of or right to use of equipment and services connected therewith.

FRANCE

29.9.1992

10

10

10

10

10% with effect from 1.4.97.

GERMANY

19.6.1995

10

10

10

10  

ITALY

19.2.1993

15

25

15

20

20

15% on Dividend where beneficial owner is company, owing at least 10% of voting stock of company 25% on Dividend in other cases.

JAPAN

7.3.1989

15

10

15

20

20 10% on interest for banks and 15% in all other cases.

MAURITIUS

24.8.1982

5

15

No rate is provided

15

No separate clause. 5% on Dividend where beneficial owner is company, owning at least 10% of capital of company 15% on Dividend in other cases.

NETHERLANDS

30.7.1988

10

10

10

10  

NEW ZEALAND

17.10.1986

15

10

10

10

Rates substituted by Notification dt.12.1.2000

SPAIN

08.02.1993

15

15

10

20  

SWISS
CONFEDERATION

02.11.1994

10

10

10

10  

U.K.

25.1.1993

15

15

First five years of effect of agreement
15

20

15

20

15% on royalties if payer is government or specified organisation; 20% in other cases
Subsequent years
15 15 15% in any case.
10 10 10% in respect of use of or right to use of equipment and services connected therewith.

USA

12.9.1989

15

25

 

 

 

10

15

 

15% on Dividend where beneficial owner is company owning at least 10% of voting stock of company. 25% on dividend in other ases. 10% on interest in case of banks 15% in other cases.

First five years of effect of agreement
15

20

15

20

15% on royalties if payer is government or specified organisation.20% on royalties in other cases.
Subsequent years
15 15 Whether payer is government or others
10 10 10% in respect of use of or right to use of equipment and services connected therewith.

Note: In most cases the aforesaid rates of tax are on gross income but in some cases, tax is levied on the net income and hence each article of the respective agreement/s must be carefully analysed and applied.

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