https://www.taxtmi.com/highlights?id=57739 Withholding rate of tax in respect of dividend - We are not impressed with the argument advanced on behalf of the revenue that since Slovenia, Lithuania, and Columbia became members of the OECD, not only after the subject DTAA came into force but also after their own DTAA came into force, and therefore, lower rate of withholding tax, i.e., 5% on dividends would not apply to recipients in the Netherlands, who are otherwise covered under the subject DTAA - as that is not how the other contracting State, i.e., the Netherlands has interpreted Clause IV (2) of the protocol appended to the subject DTAA. - HC en-us Mon, 26 Apr 2021 18:33:25 +0530 Mon, 26 Apr 2021 18:33:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=57739 Withholding rate of tax in respect of dividend - We are not impressed with the argument advanced on behalf of the revenue that since Slovenia, Lithuania, and Columbia became members of the OECD, not only after the subject DTAA came into force but also after their own DTAA came into force, and therefore, lower rate of withholding tax, i.e., 5% on dividends would not apply to recipients in the Netherlands, who are otherwise covered under the subject DTAA - as that is not how the other contracting State, i.e., the Netherlands has interpreted Clause IV (2) of the protocol appended to the subject DTAA. - HC Highlights Income Tax Mon, 26 Apr 2021 18:33:25 +0530 https://www.taxtmi.com/highlights?id=57739