July 13, 198
@ 5% on dividend income by invoking MFN Clause under India-Switzerland DTAA
f India's DTAA with Lithuania, which is also an OECD member, the Assessee is eligible for the benefit of lower withholding rate of 5%
cate @ 10% which wa
te of 5% on div
lovenia, Lithuania, and Colombia were not OECD member countries when subject Netherlands DTAA was executed and thus, granted certificate at 10% w
otocol stated that it "shall form part an integral part of the Convention" and thus, no fresh notification was requi
ribes the state of affairs when request for application u/s 197 is made, not at the time when subject DTAA was executed.
ficial rate of 5% in India-Slovenia DTAA will be applicable to recipients of Netherlands from date when Slovenia became OECD member, i.e., from August 21, 2010, although, the India-Slovenia DTAA came into force on February 17, 2005
TAA with the Netherla
dia entered into DTAA with OECD member
issue a separate notification
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