Harun Raaj & Associates · Tools

DTAA Rate Lookup

Compare treaty rates by country and income type. Outputs are indicative and must be checked against the signed treaty.

Select countryIncome typeDividend paid by Indian company to foreign resident shareholder

United States of America · dividend

Treaty Rate: 15%

15% on gross dividend (treaty rate). Domestic WHT is 20% + surcharge + cess under s.115A — treaty is more beneficial. Requires TRC + Form 10F.

Article reference: Article 10

Under s.90(2), taxpayer may apply DTAA rate or domestic rate, whichever is more beneficial.

TRC

Tax Residency Certificate (TRC) from the foreign country is required to claim DTAA benefit under s.90(4). Without TRC, domestic rates apply.

Form 10F

Form 10F must be filed on the e-filing portal if the non-resident cannot obtain a Tax Residency Certificate (TRC) from the foreign country. From Nov 2022, Form 10F filed online on the Indian e-filing portal.

VERIFY

Confirm whether Form 10F online filing mandate (CBDT Circular 10/2023 and subsequent orders) has been extended or is permanent — changes whether Form 10F must be filed before every payment or can be filed in ITR.

VERIFY

US-India DTAA was signed in 1990. A revised protocol was signed in 1989. Confirm whether there are any further protocols or amendments that changed the dividend/interest rates. Also confirm: the treaty's Limitation of Benefits provisions under Article 24 — US residents must satisfy LOB tests to claim treaty rates.