Taxation of dividend now taxed in recipients' hands, replacing company-level dividend distribution tax and altering withholding rules.
Abolition of the dividend distribution tax (DDT) shifts taxation from companies to shareholders, repealing the prior company-level levy and the exemption for dividend receipts; dividends are now taxable in recipients' hands with distinct tax incidence for resident individuals, resident corporates and non-residents, adjusted withholding obligations, revived intra-group set-off relief limited to domestic-source dividends, constraints on interest deductibility against dividend income, and consequential interactions with buyback taxation and transfer pricing secondary adjustment provisions. (AI Summary)
Abolition of the dividend distribution tax (DDT) shifts taxation from companies to shareholders, repealing the prior company-level levy and the exemption for dividend receipts; dividends are now taxable in recipients' hands with distinct tax incidence for resident individuals, resident corporates and non-residents, adjusted withholding obligations, revived intra-group set-off relief limited to domestic-source dividends, constraints on interest deductibility against dividend income, and consequential interactions with buyback taxation and transfer pricing secondary adjustment provisions. (AI Summary)
TaxTMI