Dividend TDS

Saudi Arabia

Article 10: flat 5% on Indian dividends to Saudi residents (no individual-vs-corporate sub-rate). Among the lowest dividend rates in any India DTAA, joint with Malaysia and Hong Kong. (Mauritius's 5% is corporate-only; individuals there are 15%.)

Malaysia

Article 10: 5% on Indian-listed dividends, the lowest dividend rate of any major Indian DTAA alongside Hong Kong

Hong Kong

Article 10: 5% on Indian-listed dividends to HK residents, joint-lowest with Malaysia. The single biggest hook for any Indian listed equity holder in HK.

Myanmar

Article 10(2): flat 5% cap on Indian dividends paid to a Myanmar-resident beneficial owner. There is no shareholding test, so an individual portfolio investor gets the same 5% as a company.

Fiji

Article 10(2): a flat 5% cap for any Fiji-resident beneficial owner, with no shareholding test, so individual portfolio investors get the full 5%. That is one of the lowest dividend caps in India's treaties. In Fiji, FRCS exempts an individual's dividends paid out of profits already taxed at company level, which normally covers Indian company dividends. Exempt income earns no Fiji foreign tax credit, so the 5% Indian tax is the only tax: claim the treaty rate in India, and reclaim any excess through an Indian ITR.

Colombia

Article 10(2): one flat 5% cap for any Colombia-resident beneficial owner, with no shareholding threshold, so an individual portfolio investor gets the same 5% as a company. This is one of the lowest dividend caps in India's treaties. The protocol's higher 15% rate (paragraph 2) applies only to dividends paid by Colombian companies, not Indian ones

Uruguay

Article 10(2): a flat 5% cap for any Uruguay-resident beneficial owner, with no shareholding test, so individual portfolio investors get the full 5%, one of the lowest dividend caps in India's treaties. Uruguay taxes the dividend at 12% and credits the Indian 5%.

Sri Lanka

Article 10: flat 7.5% treaty cap, one of the lowest India offers any country

Mozambique

Article 10(2): a flat 7.5% cap for any Mozambique-resident beneficial owner. There is no shareholding test and no separate company rate, so an individual portfolio investor gets the full 7.5%. Indian companies deduct 20% unless they or their registrar have your certificate of residence and Form 41 (formerly Form 10F) in time. Mozambique credits the 7.5% against its own tax on the dividend.

Ethiopia

Article 10(2): a single 7.5% cap on the gross dividend for every Ethiopia-resident beneficial owner, with no separate rate for large holdings. That is one of the lowest dividend caps in India's treaties, against India's 20% domestic rate for non-residents. Ethiopia taxes residents' dividends at 15% and credits the Indian 7.5%

UAE

Article 10

UK

Dividends article (post-2013 protocol numbering: Article 11), 10% general dividend rate for individual UK residents. The 15% sub-rate applies ONLY to dividends paid out of income derived from immovable property by an investment vehicle (REIT-type structures). Per CBDT-published TDS DTAA rate table.

Qatar

Article 10(2)(b): 10% for individuals; the 5% rate is only for companies holding at least 25%

Germany

Article 10: 10% flat rate on Indian-source dividends to resident beneficial owners (no shareholding sub-rate).

Netherlands

Article 10: 10% flat rate on Indian-source dividends to resident beneficial owners (no shareholding sub-rate).

Kuwait

Article 10

France

Article 11: 10% on portfolio dividends. The 5% MFN rate that French CAs used to claim under the 1992 protocol is NO LONGER available for India-source dividends after the Indian Supreme Court's October 2023 Nestlé SA ruling, 10% is the correct rate.

Ireland

Article 10: 10% flat rate on Indian-source dividends to resident beneficial owners (no shareholding sub-rate).

Switzerland

Article 10: 10% flat rate on Indian-source dividends to Swiss residents. The MFN-derived 5% rate is no longer self-executing post the Indian Supreme Court's October 2023 Nestlé SA ruling and Switzerland's unilateral suspension of MFN benefit from 1 January 2025; treaty rate is now 10%.

Japan

Article 10: 10% on Indian-listed dividends to Japanese residents

South Africa

Article 10

Kenya

Article 10

Sweden

Article 10: 10% flat rate on Indian-source dividends to resident beneficial owners (no shareholding sub-rate).

Norway

Article 10: 10% flat rate on Indian-source dividends to resident beneficial owners (no shareholding sub-rate).

Thailand

Article 10: 10% on Indian-listed dividends to Thai residents

Indonesia

Article 10 of the 2012 revised India-Indonesia treaty, 10% flat rate on Indian-source dividends to Indonesian residents. The 2012 protocol rationalised dividends, royalties and FTS to a uniform 10% with no shareholding sub-rate.

Luxembourg

Article 10: flat 10% treaty cap, irrespective of shareholding size

Austria

Article 10: flat 10% treaty cap on Indian-source dividends

Poland

Article 11: flat 10% treaty cap after the 2013 protocol (was 15%)

Finland

Article 10: flat 10% treaty cap (the 2010 revision cut it from 15%)

China

Article 10: flat 10% treaty cap, no shareholding sub-rate

Vietnam

Article 10: flat 10% treaty cap, no shareholding sub-rate

Israel

Article 10: flat 10% treaty cap (unchanged by the 2016 protocol)

Tanzania

Article 10: 10% general treaty cap (5% only for a company holding at least 10%)

Uganda

Article 10: flat 10% treaty cap, no shareholding sub-rate

Nepal

Article 10: 10% generally, drops to 5% only if the Nepal-resident recipient is itself a company holding at least 10% of the Indian payer's shares, an individual investor never qualifies for the lower rate

Cyprus

Article 10: flat 10% on Indian-source dividends, no shareholding-linked sub-rate the way some other treaties have

Malta

Article 10: 10% on Indian-source dividends paid to a Malta resident, no shareholding-linked sub-rate

Russia

Article 10: flat 10% on Indian-source dividends, no shareholding-linked sub-rate the way Bangladesh's treaty has

Mexico

Article 10: flat 10% on Indian-source dividends, confirmed directly from the treaty text, no shareholding-linked sub-rate

Czech Republic

Article 10(2): flat 10% cap for any Czech-resident beneficial owner, with no separate company or substantial-holding rate, so individual portfolio investors get the full 10%.

Romania

Article 10(2): flat 10% cap for any Romanian-resident beneficial owner, individual or company, with no shareholding threshold. Romania then taxes the dividend at 16% (2026) and credits the 10% Indian tax, so you pay the 6% difference in Romania.

Hungary

Article 10(2): flat 10% cap for any Hungarian-resident beneficial owner, with no shareholding sub-rate, so individual portfolio investors get the full 10%. Hungary credits the Indian tax under Article 23(1)(b).

Kazakhstan

Article 10(2): flat 10% cap on Indian dividends to a Kazakhstan-resident beneficial owner, with no shareholding-linked sub-rate, so an individual portfolio investor gets the same 10% as a company

Georgia

Article 10(2): one flat 10% cap for any Georgia-resident beneficial owner, with no shareholding threshold, so an individual portfolio investor gets the same 10% as a company

Estonia

Article 10(2): a single 10% cap on dividends beneficially owned by an Estonian resident, with no separate company rate. That is below India's 20% domestic rate on non-resident dividends. Estonia exempts foreign dividends that were taxed abroad, so the Indian 10% is normally the only tax. You still declare them on the Estonian return.

Uzbekistan

Article 10(2), as amended by Article 1 of the 2012 Protocol (15% cut to 10%): flat 10% cap on Indian dividends to an Uzbekistan-resident beneficial owner, with no shareholding-linked sub-rate, so an individual portfolio investor gets the same 10% as a company

Albania

Article 10(2): a single 10% cap on dividends paid to an Albanian-resident beneficial owner, with no shareholding sub-rate, so a portfolio investor gets 10% too. Albania taxes dividends at only 8%, so its credit stops at 8%: claim the 10% cap in India rather than relying on Albania.

Bhutan

Article 10(2): flat 10% cap on Indian dividends to a Bhutan-resident beneficial owner, with no shareholding sub-rate, so an individual portfolio investor gets the same 10% as a company

Kyrgyzstan

Article 10(2): flat 10% cap on Indian dividends to a Kyrgyz-resident beneficial owner, with no shareholding-linked sub-rate, so an individual portfolio investor gets the same 10% as a company. Kyrgyzstan exempts foreign dividends received by resident foreigners (Tax Code Article 191(7)(10-1)), so the Indian 10% is the only tax

Iceland

Article 10(2): flat 10% cap for any Iceland-resident beneficial owner, with no shareholding sub-rate, so individual portfolio investors get the full 10%. Iceland taxes the dividend at 22% and credits the Indian tax under Article 23(2)(a).

Latvia

Article 10(2): a single 10% cap on dividends beneficially owned by a Latvian resident, with no separate company rate. That is below India's 20% domestic rate on non-resident dividends. Article 23(2)(b) lets Latvia credit the Indian tax up to Latvian tax on the same dividend.

Armenia

Article 10(2): one flat 10% cap for any Armenia-resident beneficial owner, with no shareholding threshold, so an individual portfolio investor gets the same 10% as a company. The SRC guide lists a 5% Armenian rate on dividends, and the Armenian credit is capped at the Armenian tax

North Macedonia

Article 10(2): a single 10% cap on dividends paid to a beneficial owner resident in North Macedonia, with no separate rate for large shareholdings, so a portfolio investor gets 10%. North Macedonia also taxes dividends at 10% and credits the Indian tax.

Tajikistan

Article 10(2)(b): 10% cap for every beneficial owner except a company holding at least 25% of the paying company's capital, which gets 5% under Article 10(2)(a). An individual portfolio investor therefore pays 10% in India. Indian dividends are not taxed at source in Tajikistan, so they are declared there and the Indian 10% is credited

Morocco

Article 10(2): one flat 10% cap for any Morocco-resident beneficial owner, with no shareholding threshold, so an individual portfolio investor gets the same 10% as a company

Jordan

Article 10(2): one flat 10% cap for any Jordan-resident beneficial owner, with no shareholding threshold, so an individual portfolio investor gets the same 10% as a company

Chile

Article 10(2): a flat 10% cap on dividends whose beneficial owner is a Chilean resident. There is no shareholding sub-rate, so the 10% applies to every individual portfolio investor. The cap is subject to Article 28(11): where Chile does not effectively tax the dividend (for example during a newcomer's first three years), India's domestic 20% applies instead. Chile adds the dividend to your Global Complementary Tax base and credits the Indian tax under Article 22(2)(a).

Trinidad & Tobago

Article 10(2): a flat 10% cap for any Trinidad and Tobago resident beneficial owner, with no shareholding test, so individual portfolio investors get the full 10%. The local dividend exemption covers only resident companies, so a worldwide-basis resident declares Indian dividends and credits the Indian 10% under Article 23(2).

Botswana

Article 10(2)(b): 10% cap on Indian dividends for every Botswana-resident beneficial owner other than a company holding at least 25% of the payer's capital (that company rate is 7.5% under Article 10(2)(a)). An individual portfolio investor gets 10%. From July 2026 Botswana adds foreign dividends to an ordinary resident's investment income at individual rates, with credit for the Indian tax up to the Botswana tax

Iran

Article 10(2): one flat 10% cap for any Iran-resident beneficial owner, with no shareholding threshold, so an individual portfolio investor gets the same 10% as a company

Namibia

Article 10(2): 10% cap on Indian dividends for every Namibia-resident beneficial owner, with no separate rate for large holdings. Namibia exempts dividends under section 16(1)(n) of its Income Tax Act after deeming a resident's foreign dividends to be Namibian-source. Article 24(1) removes treaty relief only where Namibia exempts income because it is foreign-source, so the cap should hold, but expect an Indian payer or assessing officer to ask

Syria

Article 10(2)(b): 10% for an individual or any other beneficial owner resident in Syria. The lower 5% in Article 10(2)(a) applies only to a company (not a partnership) holding at least 10% of the Indian company's shares

Sudan

Article 10(2): a flat 10% cap on dividends from an Indian company when the Sudan-resident recipient is the beneficial owner. There is no higher rate for small holdings, so individual portfolio investors get the 10% cap too.

Turkmenistan

Article 10(2): one flat 10% cap for any Turkmen-resident beneficial owner, with no shareholding threshold, so an individual portfolio investor gets the same 10% as a company. Turkmenistan taxes the dividend as part of your taxable income and credits the Indian tax up to the Turkmen tax due on it

Oman

Article 10: 12.5% for individual NRIs in all other cases. The 10% sub-rate applies ONLY when the beneficial owner is a company holding ≥10% of the dividend-paying Indian company's shares. Per CBDT-published DTAA TDS rate table.

Taiwan

Article 10(2): a single 12.5% cap on gross dividends for any Taiwan-resident beneficial owner, individual or company. There is no separate substantial-holding rate, so portfolio investors get the full 12.5% cap against India's 20% domestic rate.

Singapore

Article 10: 15% for individual Singapore residents (the 10% sub-rate applies only when the beneficial owner is a company holding ≥25% of the dividend-paying Indian company's capital). Per CBDT DTAA TDS rate table.

Australia

Article 10: 15% on Indian-listed dividends to Australian residents

South Korea

Article 10 (revised 2015 treaty), 15% on Indian dividends to Korean residents. Flat 15% with no corporate-holding sub-rate.

New Zealand

Article 10: 15% on Indian dividends to NZ residents

Mauritius

Article 10: 15% for individual NRIs (beneficial owner not a company with ≥10% holding). The 5% sub-rate applies only to corporate beneficial owners with ≥10% capital, not individuals.

Spain

Article 11: flat 15% treaty cap on Indian-source dividends, better than the 20% domestic rate

Portugal

Article 10: 15% for an individual (10% only for a company holding at least 25% for two years)

Belgium

Article 10: flat 15% treaty cap on Indian-source dividends

Brazil

Article 10: 15% general treaty cap (10% only for a company holding at least 20% for 365 days)

Bangladesh

10% if the beneficial owner is a company holding directly at least 10% of the paying company's capital, 15% in all other cases, an individual investor always falls in the 15% bracket, not the lower one

Türkiye

Article 10(2): one flat 15% cap for any beneficial owner, with no company or shareholding threshold, so individual portfolio investors get it too. It sits below India's 20% domestic non-resident rate. Türkiye credits the Indian tax under Article 22(3)(b) for residents who do not have the Law 7582 exemption.

Ukraine

Article 10(2) is split: 10% only for a COMPANY holding directly at least 25% of the Indian payer's share capital, 15% in all other cases. An individual portfolio investor gets the 15% cap, which is below India's 20% domestic rate, so 15% applies. Ukraine taxes dividends from a non-resident company at only 9% PIT, so even at 15% part of the Indian tax cannot be credited in Ukraine.

Lithuania

Article 10(2)(b): 15% for every holder other than a company owning at least 10% of the capital (that company rate is 5% under 10(2)(a)). So an individual portfolio investor is capped at 15%, which is below India's 20% domestic rate on non-resident dividends. Lithuania taxes dividends at 15% and credits the Indian tax under Article 37 of its PIT Law.

Bulgaria

Article 11(2): a single 15% cap on dividends paid to a beneficial owner resident in Bulgaria, with no shareholding sub-rate, so a portfolio investor gets the same 15% as a company. Below India's 20% domestic rate, so 15% applies. Again only for Bulgarian nationals (Article 4(1)(b)).

Belarus

Article 10(2) has two rates: 10% only for a COMPANY holding at least 25% of the Indian payer's shares, and 15% in all other cases. An individual portfolio investor gets the 15% cap, 5 points below India's 20% domestic rate

Serbia

Article 10(2)(2): 15% cap in all cases other than a company holding at least 25% of the payer's capital, which gets 5% under 10(2)(1) (with a 365-day holding period added by MLI Article 8). A portfolio investor gets 15%, below India's 20% domestic rate.

Slovenia

Article 10(2)(b): 15% cap for every beneficial owner other than a company holding at least 10% of the Indian payer, so it covers every individual portfolio investor. The 5% rate in Article 10(2)(a) is for companies only, and MLI Article 8 adds a 365-day holding condition to it. Slovenia taxes the dividend at 25% and credits Indian tax only up to the treaty's 15%.

Croatia

Article 10(2)(b): 15% for every shareholder other than a company holding at least 10% of the capital (5% under 10(2)(a)). That 15% cap applies to individual portfolio investors and is below India's domestic 20%, so it is a real saving. Croatia taxes dividends at 12% and credits Indian tax only up to its own 12%, so 3 points of the 15% are not credited in Croatia.

Montenegro

Article 10(2)(2): 15% cap in all cases other than a company holding at least 25% of the payer's capital, which gets 5% under 10(2)(1). A portfolio investor gets 15%, below India's 20% domestic rate. The Multilateral Instrument (MLI) does not apply to this treaty, so there is no added 365-day holding test.

Mongolia

Article 10(2): a flat 15% cap on Indian dividends paid to a Mongolian-resident beneficial owner. There is no lower rate for large shareholdings, so an individual portfolio investor gets the same 15% as a company. Mongolia taxes resident dividends at 10% and credits Indian tax only up to that amount

Zambia

Article 10(2)(b): 15% cap for every shareholder except a company holding at least 25% of the paying company for the six months before payment, which gets 5% under Article 10(2)(a). An individual portfolio investor therefore pays 15% instead of India's 20% domestic rate. Zambia taxes foreign dividends of residents and credits the Indian tax