https://www.taxtmi.com/article/detailed?id=12030 The primary issue is whether DDT under section 115O is a corporate-level tax on distributed profits or a tax on shareholders, a determination that affects whether non-resident shareholders can claim treaty rates. Divergent judicial and tribunal findings have left incidence unresolved. A policy-based comparative analysis likens DDT to an independent corporate tax-grounded in the separateness of corporations and shareholders and the corporations' consumption of public goods-suggesting treaty benefits may not apply to non-resident shareholders when DDT is levied on the company's distributed profits. en-us Wed, 08 Nov 2023 12:15:47 +0530 Wed, 08 Nov 2023 12:29:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/article/detailed?id=12030 The primary issue is whether DDT under section 115O is a corporate-level tax on distributed profits or a tax on shareholders, a determination that affects whether non-resident shareholders can claim treaty rates. Divergent judicial and tribunal findings have left incidence unresolved. A policy-based comparative analysis likens DDT to an independent corporate tax-grounded in the separateness of corporations and shareholders and the corporations' consumption of public goods-suggesting treaty benefits may not apply to non-resident shareholders when DDT is levied on the company's distributed profits. Articles Income Tax Wed, 08 Nov 2023 12:15:47 +0530 https://www.taxtmi.com/article/detailed?id=12030