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Rate of DDT should not exceed rate specified in Article 10 in India-Germany DTAA: ITAT

October 22, 2020[2020] 120 338 (Delhi - Trib.)

INTERNATIONAL TAXATION : DDT, a levy on dividend distributed by payer company, being an additional tax, is covered by definition of 'tax' as defined under section 2(43) which is covered by charging section 4 and charging section itself is subject to provisions of Act which would include section 90 and liability to DDT under Act which falls on company may not be relevant when considering applicability of rates of dividend tax set out in tax treaties; generally accepted principles relating to interpretation of treaties in light of object of eliminating double taxation, does not bar application of tax treaties to DDT and, thus, tax rates specified in DTAA in respect of dividend must prevail over DDT

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