What is DTAA and how does it benefit taxpayers?

DTAA (Double Tax Avoidance Agreement) is a bilateral treaty between India and another country to prevent the same income from being taxed twice. It specifies reduced withholding tax rates on dividends, interest, royalties, and fees for technical services (FTS). A foreign company receiving income from India can claim DTAA benefits to pay lower withholding tax than the domestic rate.

What is the DTAA withholding tax rate on dividends between India and the USA?

Under the India–USA DTAA, the withholding tax on dividends is 25% (or 15% if the beneficial owner holds at least 10% of the voting stock). The domestic rate under Indian law is 20% plus surcharge and cess. The lower of the DTAA rate and domestic rate applies.

How do I claim DTAA benefits in India?

To claim DTAA benefits, the foreign recipient must provide a Tax Residency Certificate (TRC) issued by the tax authority of their home country and Form 10F (self-declaration). Without these documents, the payer must deduct TDS at the higher domestic rate under Section 206AA.

Does DTAA override domestic tax law in India?

Yes. Section 90 of the Income Tax Act allows a taxpayer to apply whichever is more beneficial — the DTAA rate or the domestic tax rate. However, the General Anti-Avoidance Rules (GAAR) can override DTAA benefits if the arrangement is deemed to be primarily for tax avoidance.

What is the India–Singapore DTAA withholding tax rate on royalties?

Under the India–Singapore DTAA, royalties and fees for technical services (FTS) are taxed at 10%. This is lower than the Indian domestic rate of 20% (plus surcharge and cess), making Singapore a common treaty jurisdiction for IP holding structures.

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90+ Countries

DTAA Rate Finder

India's Double Tax Avoidance Agreement withholding tax rates — dividends, interest, royalties and FTS with 88+ treaty countries.

When a foreign company or individual receives income from India — dividends, interest, royalties, or fees for technical services — they are ordinarily subject to Indian withholding tax (TDS) at domestic rates, which can be as high as 40% for foreign companies. India's network of Double Tax Avoidance Agreements (DTAAs) with over 90 countries allows qualifying non-residents to reduce this withholding tax to treaty-specified rates — often 10–15% on dividends and interest, and 10% on royalties — provided the correct documentation is in place.

To claim treaty benefits, a non-resident must hold a valid Tax Residency Certificate (TRC) issued by the tax authority of their home country. They must also file Form 10F with the Indian payer before the payment is made. Without these documents, the Indian payer is required to deduct TDS at the higher domestic rate under Section 206AA. The treaty rate applies only if the non-resident is the "beneficial owner" of the income — conduit arrangements or pass-through structures may be challenged by Indian tax authorities under General Anti-Avoidance Rules (GAAR).

DTAA rates vary significantly by country and income type. For example, India's treaty with Singapore provides a 10% rate on dividends for substantial holdings, while the treaty with Mauritius offers different rates depending on the payment type. Some treaties also provide a "Most Favoured Nation" (MFN) clause, which may entitle the non-resident to rates lower than those explicitly listed in the treaty if India signs a more favourable treaty with another OECD country. The MFN clause requires careful analysis and has been subject to recent judicial controversy in India.

This DTAA Rate Finder covers withholding tax rates for four income categories — dividends, interest, royalties, and fees for technical services (FTS) — across all major treaty countries, with notes on specific conditions and TRC requirements. For non-resident payments under Section 195, use this tool alongside our TDS Rate Chart to compare treaty rates against domestic rates and determine the applicable deduction rate. Built by our Ex-Big 4 CA team based on current India DTAA schedules.

1. Get TRC

Obtain a Tax Residency Certificate from the treaty country's tax authority.

2. File Form 10F

Submit Form 10F with the Indian payer before payment is made.

3. Claim Lower Rate

Payer deducts TDS at the treaty rate instead of the domestic rate.

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88 countries

Country	Dividend	Interest	Royalties	FTS	TRC Reqd	Key Notes
🇦🇺 Australia Asia-Pacific	15%	15%	10%/15%	10%/15%	Yes	FTS rate 10% for make-available; 15% otherwise. MLI in force. PPT applies.
🇦🇹 Austria Europe	10%	10%	10%	10%	Yes	MLI in force. PPT applies. Protocol updated in 2001.
🇧🇩 Bangladesh South Asia	10%/15%	10%	10%	N/A	Yes	10% dividend if >10% holding; 15% otherwise. Treaty predates MLI.
🇧🇭 Bahrain Middle East	N/A	N/A	10%	10%	Yes	Limited treaty — covers royalties and FTS only. No withholding on dividends/interest.
🇧🇾 Belarus Europe	10%/15%	10%	15%	15%	Yes	10% dividend for >25% holding; 15% otherwise. Treaty signed 1997.
🇧🇪 Belgium Europe	15%	15%	10%	10%	Yes	MLI in force. PPT and SLOB apply. Protocol revised 1993.
🇧🇷 Brazil Americas	15%	15%	15%/25%	N/A	Yes	No DTAA in force — domestic rates apply. Withholding at 15% standard; 25% for tax haven remittances.
🇨🇦 Canada Americas	15%/25%	15%	10%/15%	10%/15%	Yes	15% dividend for >10% voting shares; 25% otherwise. FTS 10% if make-available, else 15%. MLI in force.
🇨🇳 China Asia-Pacific	10%	10%	10%	10%	Yes	Revised treaty effective 2018. MLI not applicable (bilateral renegotiation used).
🇨🇾 Cyprus Europe	10%	10%	10%	10%	Yes	Revised DTAA effective 2017. Earlier treaty notified as Limited; new treaty has LOB-type clause.
🇨🇿 Czech Republic Europe	10%	10%	10%	10%	Yes	MLI in force. PPT applies. Treaty signed 1998.
🇩🇰 Denmark Europe	15%/25%	15%	20%	20%	Yes	MLI in force. PPT applies. Older treaty — royalty rate 20%.
🇪🇬 Egypt Africa	N/A	N/A	N/A	N/A	No	No comprehensive DTAA in force. Limited agreement on air transport only.
🇪🇹 Ethiopia Africa	N/A	N/A	N/A	N/A	No	No DTAA in force. Domestic Indian withholding rates apply.
🇫🇮 Finland Europe	10%	10%	10%	10%	Yes	MLI in force. PPT applies. Revised treaty effective 2012.
🇫🇷 France Europe	10%	10%	10%	10%	Yes	MLI in force. PPT applies. Revised treaty effective 1994; protocol added 2000.
🇩🇪 Germany Europe	10%	10%	10%	10%	Yes	MLI in force. PPT applies. Updated protocol 1996. One of India's most used treaties.
🇬🇷 Greece Europe	N/A	N/A	N/A	N/A	No	No DTAA in force. Domestic Indian withholding rates apply.
🇭🇰 Hong Kong Asia-Pacific	5%	10%	10%	10%	Yes	DTAA effective 2018. 5% dividend for >10% holding. LOB article included.
🇭🇺 Hungary Europe	10%	10%	10%	10%	Yes	MLI in force. PPT applies.
🇮🇩 Indonesia Asia-Pacific	10%	10%	15%	N/A	Yes	No specific FTS article; may fall under royalties. Treaty signed 1987.
🇮🇪 Ireland Europe	10%	10%	10%	10%	Yes	MLI in force. PPT applies. Important for technology and financial services.
🇮🇱 Israel Middle East	10%	10%	10%	10%	Yes	Treaty signed 1996, effective 1994. No MLI.
🇮🇹 Italy Europe	15%/25%	15%	20%	20%	Yes	MLI in force. PPT applies. Older treaty — higher royalty rate.
🇯🇵 Japan Asia-Pacific	10%	10%	10%	10%	Yes	Revised treaty effective 2007. MLI in force. PPT applies. Key for Japanese investments in India.
🇯🇴 Jordan Middle East	10%	10%	20%	20%	Yes	Treaty signed 1999. No MLI. Royalty rate relatively high at 20%.
🇰🇿 Kazakhstan Central Asia	10%	10%	10%	10%	Yes	Treaty effective 1997. No MLI currently.
🇰🇪 Kenya Africa	15%	15%	20%	17.5%	Yes	Treaty signed 1985. No MLI. One of few Africa DTAAs India has.
🇰🇷 South Korea Asia-Pacific	15%	10%	10%	10%	Yes	MLI in force. PPT applies. Important for Korean manufacturing investments.
🇰🇼 Kuwait Middle East	10%	10%	10%	10%	Yes	Treaty effective 2008. No MLI. Key for Kuwaiti sovereign wealth flows.
🇱🇻 Latvia Europe	10%	10%	10%	10%	Yes	MLI in force. PPT applies.
🇱🇹 Lithuania Europe	10%	10%	10%	10%	Yes	MLI in force. PPT applies.
🇱🇺 Luxembourg Europe	10%	10%	10%	10%	Yes	MLI in force. PPT applies. Key for European fund structures.
🇲🇾 Malaysia Asia-Pacific	N/A	10%	10%	10%	Yes	No withholding on dividends (exemption method). Treaty signed 1976, amended 2012.
🇲🇹 Malta Europe	10%	10%	10%	10%	Yes	MLI in force. PPT applies. Treaty effective 1994.
🇲🇺 Mauritius Africa	5%/15%	7.5%	15%	N/A	Yes	Revised DTAA effective 2017. 5% dividend for >10% shareholding. Capital gains on shares acquired after 1 Apr 2017 taxable in India. TRC mandatory. Grandfathering until 31 Mar 2019.
🇲🇽 Mexico Americas	10%	10%	10%	10%	Yes	Treaty effective 2010. MLI in force. PPT applies.
🇲🇳 Mongolia Asia-Pacific	15%	15%	15%	N/A	Yes	Treaty signed 1994. No MLI.
🇲🇦 Morocco Africa	10%	10%	10%	10%	Yes	Treaty signed 1999, effective 1999. No MLI.
🇲🇲 Myanmar Asia-Pacific	N/A	N/A	N/A	N/A	No	No comprehensive DTAA in force.
🇳🇵 Nepal South Asia	N/A	N/A	N/A	N/A	No	No comprehensive DTAA in force. Limited air services agreement only.
🇳🇱 Netherlands Europe	10%	10%	10%	10%	Yes	MLI in force. PPT applies. Key conduit country; stricter PPT means treaty shopping harder. Updated 2012.
🇳🇿 New Zealand Asia-Pacific	15%	10%	10%	10%	Yes	MLI in force. PPT applies. Treaty effective 1986.
🇳🇴 Norway Europe	15%/25%	15%	10%	10%	Yes	MLI in force. PPT applies. Older treaty.
🇴🇲 Oman Middle East	10%/12.5%	10%	15%	15%	Yes	10% dividend for >10% holding; 12.5% otherwise. Treaty effective 1997.
🇵🇭 Philippines Asia-Pacific	15%/20%	10%/15%	15%	N/A	Yes	15% dividend if >10% holding, 20% otherwise. Interest 10% for government/bank; 15% others. No MLI.
🇵🇱 Poland Europe	15%	15%	22.5%	22.5%	Yes	MLI in force. PPT applies. Older treaty — high royalty rate. Protocol signed 2013.
🇵🇹 Portugal Europe	10%/15%	10%	10%	10%	Yes	MLI in force. PPT applies. Treaty effective 2010.
🇶🇦 Qatar Middle East	5%/10%	10%	10%	10%	Yes	5% dividend for >10% holding; 10% otherwise. Treaty effective 2000. Key for Qatar Investment Authority flows.
🇷🇴 Romania Europe	N/A	N/A	N/A	N/A	No	Treaty being renegotiated. Older treaty (1987) has limited applicability.
🇷🇺 Russia Europe	10%	10%	10%	10%	Yes	MLI in force. PPT applies. Treaty revised 1997. Recent geopolitical developments may affect applicability.
🇸🇦 Saudi Arabia Middle East	N/A	N/A	N/A	N/A	No	No comprehensive DTAA. Limited investment protection agreement exists. Negotiations ongoing.
🇸🇬 Singapore Asia-Pacific	10%/15%	10%/15%	10%/15%	10%/15%	Yes	Revised DTAA effective 2017. 10% rates require meeting LOB conditions (active business, listed entity, etc.). Capital gains on shares acquired after 1 Apr 2017 taxable in India. PPT now applies via MLI.
🇸🇮 Slovenia Europe	N/A	N/A	N/A	N/A	No	Treaty signed but not yet in force.
🇿🇦 South Africa Africa	10%	10%	10%	10%	Yes	MLI in force. PPT applies. Treaty effective 1998.
🇪🇸 Spain Europe	15%	15%	10%/20%	10%/20%	Yes	MLI in force. PPT applies. 10% royalty for equipment royalties; 20% others.
🇱🇰 Sri Lanka South Asia	7.5%/15%	10%	10%	10%	Yes	7.5% dividend for >10% holding; 15% otherwise. Treaty signed 2013, effective 2016.
🇸🇪 Sweden Europe	10%	10%	10%	10%	Yes	MLI in force. PPT applies. Treaty revised 1997.
🇨🇭 Switzerland Europe	10%	10%	10%	10%	Yes	MLI in force. PPT applies. MFN clause triggered — rates reduced to 10% after Mauritius/Slovenia treaties. Key for pharma and financial sector.
🇹🇿 Tanzania Africa	N/A	N/A	N/A	N/A	No	No DTAA in force.
🇹🇭 Thailand Asia-Pacific	10%	10%/25%	10%/15%	N/A	Yes	Interest 10% for banks/financial institutions; 25% others. Royalty 10% for equipment; 15% others. No MLI.
🇹🇹 Trinidad and Tobago Americas	N/A	N/A	N/A	N/A	No	No DTAA in force.
🇹🇷 Turkey Europe	15%	10%/15%	15%	15%	Yes	MLI in force. PPT applies. Interest 10% for financial institutions; 15% others.
🇦🇪 UAE Middle East	N/A	N/A	N/A	N/A	Yes	Existing DTAA covers air transport only. UAE does not levy personal income tax — comprehensive DTAA being negotiated. Domestic withholding rates apply for royalties etc.
🇬🇧 UK Europe	15%	15%	15%	15%	Yes	MLI in force. PPT applies. Original treaty 1981; Protocol 1993. UK-India renegotiation ongoing post-Brexit. 15% cap on most payments.
🇺🇦 Ukraine Europe	10%/15%	10%	10%	10%	Yes	10% dividend for >25% holding; 15% otherwise. Treaty effective 1999.
🇺🇸 USA Americas	15%/25%	15%	10%/15%	10%/15%	Yes	15% dividend for >10% voting; 25% otherwise. FTS 10% for make-available; 15% otherwise. USA has not adopted MLI. Treaty signed 1989. LOB article in treaty.
🇺🇿 Uzbekistan Central Asia	15%	15%	15%	N/A	Yes	Treaty signed 1994. No MLI.
🇻🇳 Vietnam Asia-Pacific	10%	10%	10%	10%	Yes	Treaty effective 1995. No MLI. Important for India-Vietnam manufacturing corridor.
🇿🇲 Zambia Africa	N/A	N/A	N/A	N/A	No	No DTAA in force.
🇦🇷 Argentina Americas	N/A	N/A	N/A	N/A	No	No DTAA in force. Domestic Indian withholding rates apply.
🇪🇪 Estonia Europe	10%	10%	10%	10%	Yes	MLI in force. PPT applies.
🇸🇰 Slovakia Europe	N/A	N/A	N/A	N/A	No	Treaty with former Czechoslovakia applies; applicability debated. Renegotiation pending.
🇭🇷 Croatia Europe	N/A	N/A	N/A	N/A	No	No DTAA in force.
🇷🇸 Serbia Europe	N/A	N/A	N/A	N/A	No	Treaty with former Yugoslavia may apply; status uncertain. Renegotiation recommended.
🇧🇦 Bosnia and Herzegovina Europe	N/A	N/A	N/A	N/A	No	No DTAA in force.
🇰🇬 Kyrgyzstan Central Asia	N/A	N/A	N/A	N/A	No	No DTAA in force.
🇦🇲 Armenia Central Asia	N/A	N/A	N/A	N/A	No	No DTAA in force.
🇬🇪 Georgia Central Asia	N/A	N/A	N/A	N/A	No	No DTAA in force.
🇦🇿 Azerbaijan Central Asia	N/A	N/A	N/A	N/A	No	No DTAA in force. Negotiations reported.
🇵🇰 Pakistan South Asia	N/A	N/A	N/A	N/A	No	DTAA suspended. Domestic rates apply. See Section 90 of Income Tax Act.
🇬🇭 Ghana Africa	N/A	N/A	N/A	N/A	No	No DTAA in force.
🇳🇬 Nigeria Africa	N/A	N/A	N/A	N/A	No	No DTAA in force. Negotiations ongoing.
🇩🇿 Algeria Africa	N/A	N/A	N/A	N/A	No	No DTAA in force.
🇹🇳 Tunisia Africa	N/A	N/A	N/A	N/A	No	No DTAA in force.
🇱🇾 Libya Africa	N/A	N/A	N/A	N/A	No	No DTAA in force.
🇰🇭 Cambodia Asia-Pacific	N/A	N/A	N/A	N/A	No	No DTAA in force.
🇲🇲 Myanmar Asia-Pacific	N/A	N/A	N/A	N/A	No	No DTAA in force.

Disclaimer: Rates shown are treaty rates and may not reflect recent amendments or MLI modifications. Domestic withholding rates apply if higher or if TRC is not furnished. Always consult a CA for specific transactions.