SPECIAL PROVISION FOR NRI’S – CHAPTER
XIIA:
With a view to attract
investment by NRIs and Indian Nationals living abroad, certain reliefs,
exemptions
and incentives have been provided in the Scheme of Income
taxation. Chapter XIIA of the Income-tax
Act
contains special provisions relating to taxation of Non-resident Indians.
(1)
Sec. 115C –
Definitions:
·
NRI - means an Individual, being a
citizen of India or a person of Indian origin, who is ‘Not a
Resident’.
· Investment
income – income derived from
a foreign exchange asset.
· Foreign exchange assets – specified asset
acquired by NRI out of convertible foreign exchange.
· Specified assets are –
-
Shares of an Indian Company
-
Debentures of or deposit with an Indian company not being an
private company.
-
Any security of the Central Government.
-
Other notified assets (no such asset has yet been notified).
(2)
Sec. 115D & E –
Computation of income:
| Particulars
|
Type of
Investment Income/Long Term capital |
Other Income
|
Investment
Income/Long Term capital Gains + Other Income
|
|
(a) Chapter VI
A deductions
|
Not available
|
Available
|
Available only
on other income |
| (b) Tax Rates
|
20% flat
|
Normal
rates |
10% on Long Term
Capital Gain plus 20% flat on investment income plus Tax at normal
rates on other income |
(3)
Sec. 115F – Exemptions for Long Term Capital Gains:
Capital gains arising
on transfer of a specified asset, is exempt from levy of any tax on
fulfillment of
the following conditions:
·
The asset transferred
must be a long term capital asset.
·
Net consideration must
be invested in certain specified assets.
·
Investments to be made
within six months of transfer.
·
If
only a portion of net consideration is reinvested, then proportionate
exemption
is
allowed.
·
New asset must be held
for at least three years.
(4)
Sec. 115G – Option not to file Income-tax Return:
NRI need not furnish a return of his
income, if –
·
His total income
consists only of investment incomes or income by way of Long
Term
Capital
Gains or both, and
·
TDS has been deducted
from such income.
(5)
Sec. 115H – Continuance after NRI becomes resident:
Chapter XIIA shall
continue to apply to such income even after an NRI becomes a Resident,
if he furnishes a declaration along with the Return of income to that
effect. Tax would than
be
levied at 20% until transfer/conversion into money of such assets.
(6)
Sec. 115-I – NRI may opt out of special provisions:
An NRI may elect not
to be governed by the provision of Chapter XIIA for any Assessment Year
by
furnishing written declaration to the Assessing Officer with his
return of income. His total income for
that assessment year shall be
computed and tax on such total income shall be charged in accordance
with the other provisions of the Act.
(7)
TAXATION OF AMERICAN DEPOSITORY RECEIPTS
(ADRs):
Section 115AC of the
Income-tax Act, 1961 and the guidelines issued by the Government of
India,
Issue of FCCBs and Ordinary Shares Scheme, 1993, in cohesion
govern the taxation of American
Depository Receipts i.e. ADRs. These guidelines throw light on
the tax implication on a ADR holder
at various point and form of
holding which are mentioned below:-
(1)
Trading in ADRs outside India among non-resident
investors:
As per these
guidelines all such transactions will be exempt from tax in India.
(2)
Redemption of ADRs
into underlying shares:
At the time of such
redemption there are no tax implications. After redemption of ADRs
into
underlying shares, if the non-resident continues to hold such shares, he
will not be
denied benefits under section 115AC.
(3)
Capital gains on sale
of underlying shares:
Capital
gain arising on the transfer of such shares in India will be liable for
tax in the hands
of non-resident investors. The nature of such
capital gain, whether short term or long term,
will depend upon the
period of holding of such shares. Period of holding of such shares
will be counted from the date of advice of redemption by overseas
depository to the Indian
custodian. If shares are held for less
than 12 months then it is a short term capital gain
otherwise it’s a
long term capital gain. For computation of the capital gains cost of
acquisition of such shares is taken as market price of shares on BSE
or NSE on the date
of the advice. As per the provisions of sec.
115AC such long term capital gains are
taxed at a concessional rate of
10% and short term capital gains are taxed at normal rates.
By Finance
Act, 1999 a new sub section (5) has been inserted in the section 115AC
so
as to extend benefits of sec. 115AC even to the shares in the
amalgamated company or
the resulting company in case of demerger, which
are received by the investors by
virtue of their shareholding in the
Indian company offering ADRs.
(4)
Distribution of additional ADRs etc.:
Distribution of
additional ADRs or equity shares or rights in respect of ADRs is not
taxable
in India.
(5)
Application of Tax
Treaty:
While the fiduciary
ownership of ADRs is with the overseas depository the tax treaty
applicable to such
depository will also govern the individual
investor. After redemption
till the time such shares are sold the
treaty applicable to individual
investor will be applicable.
(8)
SPECIAL CONCESSIONS FOR CAPITAL GAINS (SPECIFIED
ASSETS):
Explanation to Sec.
48(1)(a):
Convert original cost, expenditure on transfer and sale
consideration
into foreign currency in which investment was made (at
prescribed rates) and reconvert capital gains
into rupees again. The benefit of indexation will not
be available to the NRI.
(9)
PRESUMPTIVE TAXATION OF
NON-RESIDENT:
In order to facilitate
assessment and avoid difficulties involved in adducing evidence to
the
satisfaction of the Assessing Officer, taxable business profit of
Non-resident are computed not on actual
basis but by applying a
prescribed rate on gross receipts.
Rate of taxation
|
Sr.No. |
Nature of Income |
Prescribed rate of taxation |
|
(1) |
(2) |
(3) |
|
1 |
Profit and gains
of shipping business – [Sec.44B] |
Flat rate of
7 ½ % of the amount paid, payable, received or receivable to
the assessee on account of the carriage of passengers, live stock,
mail, goods shipped at any part in India, including amount by way of
demurrage or handling charges or amount of similar nature.
|
|
2 |
Profits and
gains of business of exploration etc. of mineral oils [Sec.
44BB] |
10%of
amount paid or payable, received or receivable on account of
services and facilities provided to or on account of supply of plant
and machinery on hire to be used in such business.
|
|
3 |
Profits and
gains of the business of operation of Aircraft
[Sec.44BBA] |
5% of the
aggregate of the amount paid or payable to him on account of the
carriage or passengers, live stock, mail or goods from any place in
India. |
|
4 |
Profits and
gains of foreign companies engaged in the business of Civil
Construction etc. in certain Turnkey Power Projects [Sec.
44BBB] |
10% of
the amount paid or payable to it on account of such Civil
Construction creation, testing and commissioning of the project is
approved by Central Government and is financed under any
International aid Program. |
|
5 |
Profit of
foreign telecasting companies [Circular
No.742] |
10% of
the gross receipt meant for remittance abroad or the income returned
by them whichever is higher. |
|
6 |
Income of Non-resident Sportsman or
Sports Association [Sec.115BBA] |
10% on
gross receipt of a Non-resident Sportsman who is not citizen of
India in respect of his participation in India.
|
|
|
|
|
(10)
DEDUCTION OF TAX AT SOURCE FROM PAYMENTS TO
NON-RESIDENT:
Any person responsible
for making any payment (except dividend declared after 1.6.97) to a
non-resident
individual or a foreign company is required to deduct tax
at source at the prescribed rate at the time of
credit of such income
to the account of the payee or at the time of payment thereof. If, however, person
responsible
for making the payment is the government, public sector bank or public
financial institutions,
deduction is to be made at the time of payment
only.
Where the person
responsible for making such payments considers that the whole of such sum
would not
be income chargeable in the case of recipient, he may make an
application to the Assessing Officer to
determine the appropriate
proportion of such sum which will be chargeable to tax and upon
such
determination tax is required to be deducted only on the
chargeable proportion.
The rate at which tax
is to be deducted at source will be the rates as specified in the Finance
Act of the
relevant year or rate specified in any agreement for
avoidance of double tax whichever is beneficial to the
assessee. However, in respect of income
arising to offshore fund (Overseas Financial Organization
Fund),
foreign currency convertible Bonds and ordinary shares (through Depository
Receipt Mechanism
Scheme, 1993), tax is deductible at the rates at
which such income is taxable.
For certain
remittances like interest (not being interest on securities) or any other
sum chargeable under
Income-tax Act (not being salary), the Reserve
Bank of India Exchange Control Manual requires
production of a no
objection certificate from the Income-tax authorities. The Central Board of
Direct
Taxes, vide Circular No. 759 and 767, has simplified the
procedure by dispensing with such requirement.
The person making the
remittance has only to furnish an undertaking (in duplicate) addressed to
the
Assessing Officer, which should be accompanied by a certificate
from a Chartered Accountant in the
prescribed form. The undertaking should be
submitted to the Reserve Bank of India or the authorized dealer
in
foreign exchange who will forward a copy to the Assessing Officer.
Any tax deducted in
excess of the required amount is normally refundable to the non-resident
on making
a proper claim for it.
Sometimes the non-resident returns the amount in respect of which
tax was
deducted or, circumstances occur in which tax is found to be
non-deductible or, in which tax is found to
have been deducted in
excess and the non-resident is either not able to claim refund or does not
show
initiative in claiming such refund. In such cases, the CBDT has by
Circular dated 6.8.1998 permitted refund
of excess tax to the person
making the deduction.
(11)
ASSESSMENT OF NON-RESIDENTS THROUGH ‘AGENTS’ [Sec.
163]:
A non-resident may be
assessed to tax in India either directly or through agents. Persons in India who may
be
treated as ‘agent’ of a non-resident are:-
(i)
employee or trustee of the
non-resident;
(ii)
any person who has any business connection with the
non-resident;
(iii)
any person from or through whom the non-resident is in receipt of
any income;
(iv)
any person who has acquired a capital asset in India from the
non-resident.
A broker in India who has
independent dealings with a non-resident broker acting on behalf of a
non-resident
principal is, however, not treated as an ‘agent’ of the
non-resident, if the transactions between the two
brokers are carried
on in the ordinary course of their business.
Before any
person is treated as an ‘agent’ of non-resident, he is given an
opportunity of being heard
and any representation from him in the
matter is considered.
(12) TAX
CLEARANCE CERTIFICATE BEFORE DEPARTURE FROM
INDIA:
The following
categories of persons are required to produce a tax clearance certificate
from the concerned
Assessing Officer prior to their departure:-
(a)
persons who are not domiciled in India, and in whose case the stay
in India has exceeded
120
days;
(b)
persons of Indian or non-Indian domicile whose names have been
communicated to the
airlines/shipping
Companies by the Income-tax
authorities;
(c)
persons who are domiciled in India at the time of their departure;
but
(i)
intend to leave India as emigrants; or
(ii)
intend to proceed to another country on a work permit with the
object of taking
any employment
or other occupation in that country; or
(iii) in
respect of whom circumstances exist, which in the opinion of the income
tax
authorities
render it necessary for him to obtain the Tax Clearance
Certificate.
Such certificates is
granted where there are no outstanding taxes under the Income Tax Act, the
Excess
Profits Tax Act, the Business Profits Tax Act, the Wealth Tax
Act, the Expenditure Tax Act or the
Gift Tax Act against him or where
satisfactory arrangements have been made for the payment of any
such
taxes. Obtaining guarantee
from the employer of the person leaving the country is one of
the
methods of ensuring satisfactory arrangement for payment of
taxes. For those who have to
go abroad
frequently for employer’s work, facility of one time
clearance certificate has been provided to the foreign
employee who
has a fixed tenure of service in India or upto 5 years on furnishing an
employer’s
guarantee in the prescribed form for payment of any tax
that may be found due against him during the
entire period of contract
plus two years.
(13)
WITHHOLDING TAX:
In many cases the
income earned specially by Non-residents is subject to withholding tax
provisions
commonly called as provisions for Tax Deducted at Source
(TDS). As regards TDS is
concerned, the
position is that the Non-resident seller can repatriate
immediately the funds to the extent of the cost of
acquisition of
investment sold or the actual amount of sale proceeds realized, whichever
is less, without
production of a tax clearance certificate from the
Indian tax authorities. In
cases of long term capital gains,
where the designated bank under
Sec.204 of the Income-tax Act, deducts tax @ 20% from long term
capital gains in respect of foreign exchange assets, the balance that
the entire cost plus 80% of long
term capital gains can be remitted to
the Non-resident Indian or credited to his NRE/FCNR account. The
facility of repatriation of
sale proceeds will be available only if the investment is reiterated by
the
Non-resident holding for a period of at least one year for shares
or in other securities listed in a
recognized Stock Exchange in India
or a unit of Unit Trust of India or a unit of Mutual Funds specified
under sec. 10(23D) and three years for other assets from the date of
registration of the holding in his name
or in the name of designated
bank or the latter’s name.
The recent amendments have extended the
benefit of exemption to
the hedging transaction charges on account of currency fluctuation
from
withholding of tax. [Explanation 2 to section 10(15)(iv)
]
As regards short term capital gains, the bank would
not credit the sale proceeds to NRE account or would
not remit the
funds abroad and would insist on payment of tax which the Non-resident
would be sold,
advised to pay in the form of advance tax.
For royalty and fee for technical services derived in
India also, there are TDS provisions that by and large are
the same as
the rates of tax for such category of income.
(14)
ADVANCE RULINGS:
In order to help the
tax-payers to plan their Income-tax affairs well in advance and to avoid
long drawn
out and expensive litigation, a scheme of Advance Rulings
has been introduced under the Income-tax
Act w.e.f. 1.6.1993. An Authority for Advance Rulings
has been constituted for this purpose. The
tax-payer can obtain a
binding ruling from the Authority on issues which could arise in the
determination
of his tax liability.
Authority for Advance Rulings:
The
Authority for Advance Rulings consists of a Chairman who is a retired
Judge of the Supreme Court,
and an officer of the Indian Revenue
Service who is qualified to be a member of the Central Board of
Direct
Taxes and an officer of the Indian Legal Service who is, or is
qualified to be, an Additional Secretary of the
Government of India as
members. The office of the
Authority is at Delhi and its address is mentioned below:-
Authority for Advance Rulings,
5th Floor, NDMC Building,
Yaswant Place,
Satya Marg,
Chanakyapuri,
New Delhi.
Eligible
applicants:
Any person who –
·
Is
a Non-resident or
·
Is
a resident falling within any such class or category of persons as
notified by
the Central Government in
this behalf
Can apply to the
Authority for Advance Rulings.
The Central
Government has notified the following classes of residents in this
behalf:-
(a)
Public Sector Companies
(b)
Persons seeking advance rulings in relation to the tax liability of
a non-resident
arising out of a transaction
undertaken or proposed to be undertaken by him
with a non-resident.
Scope of Advance
Rulings:
(1)
For Non-Resident
applicants:
A non-resident applicant can seek
advance ruling on any question of law or fact specified in
the
application in relation to a transaction, which has been undertaken
or is proposed to be undertaken
by the non-resident applicant. He cannot, however, seek advance
ruling where the question
i)
is already pending in his case before any Income-tax authority, the
Appellate Tribunal or
any
Court or
ii)
involves determination of fair market value of any property or
iii)
relates to a transaction which is designed prima facie for the
avoidance of Income-tax.
(2)
For Resident
Applicants:
A
resident applicant may seek an advance ruling on any question of law or
fact arising out of an
assessment
which is pending before any Income-tax authority or the Tribunal.
Procedure for filing
application:
An
applicant may seek advance ruling by making an application to the
Authority for Advance Ruling in quadruplicate. The application should be
accompanied by a fee of Rs.2,500/- to be paid through a
bank draft. The
forms to be used are as mentioned below:-
(i)
In respect of a Non-resident applicant – Form No. 34C
(ii)
In respect of a person seeking advance ruling in relation to the
tax liability of a
Non-resident arising out of transactions undertaken
or proposed to be undertaken by him
with a Non-resident – Form No.34D
(iii)
In respect of a resident falling within any such classes or
category of person as notified
by Central Government for the purposes
of sub-clause (ii) of clause (b) of Section 245N –
Form No.34E
The above forms are
available in the Forms pages of this site.
The
application should clearly state the question on which the advance ruling
is sought. An
applicant may
withdraw an application within 35 days from the date of the
application.
Procedure followed by the Authority for Advance
Rulings:
On receipt of an
application the Authority forwards a copy of the same to the Commissioner
of Income-tax.
If found
necessary, the Authority may also require the Commissioner to furnish the
relevant records. After
examining the application and the records called for, if any, the
Authority may either allow the application to
be proceeded with or may
reject the application. The
application will not be rejected without affording an
opportunity of
being heard to the applicant.
Where an application is allowed to be proceeded with,
the
Authority will pronounce its advance ruling in writing on the
question specified in the application within six
months of the receipt
of the application. A copy of
the advance ruling duly signed and certified will be sent
to the
applicant and to the Commissioner of Income-tax.
Effect of application and Advance
Rulings:
Where an application
is made by a resident applicant, no Income-tax authority or the Appellate
Tribunal
shall proceed to decide any issue in respect of which the
said application has been made.
The Advance
Ruling pronounced by the Authority shall be binding only –
(a)
on the applicant who had sought it;
(b)
in respect of the transaction in relation to which the ruling had
been sought and
(c)
on the Commissioner of Income-tax and Income-tax Authorities
subordinate to him in
respect of
the applicant and the said transaction.
The advance ruling
shall be binding as aforesaid unless there is a change in law or facts on
the
basis of which the advance ruling has been pronounced.
Where to get
assistance:
·
Website : http://www.nic.in/finmin/new%20intax.htm
·
Fax No.
0091-11-611-3407
·
E-Mail: avipra@del2.vsnl.net.in
·
Phone Nos. 0091-11-611
7802, 0091-11-611 7935
·
Mail to: The Additional Commissioner of
Income-tax,
Authority for Advance
Ruling,
5th Floor,
NDMC Building,
Yashwant Place, Satya
Marg,
Chanakya
Puri,
New Delhi
– 110 021,
INDIA.
For assistance, the
above Additional Commissioner of Income-tax may be contacted
personally
or on Telephone between 11.00 A.M. and 1.00 P.M. on any working day.
(15)
IMPORTANT AREAS OF INVESTMENT FOR
NRI:
(1)
Infrastructure facilities [Sec.
80-IA]
Enterprises carrying
on business of developing, maintaining and operating infrastructure
facility
(such as Road, Highway Bridges, Airport, Rail system etc. on
BOT, BOOT or similar basis)
which is owned by a Company under agreement
with Government or any statutory authority
and which makes such
facility operational after 1.4.1995 is entitled for deduction at
100%
of profit for initial five years and 30% thereafter so that the
deduction will be available for 10
consecutive assessment years. This
period will be 20 years in respect of Water supply,
Irrigation,
Sanitation and Sewerage project.
This deduction also applies to Housing or other
activities which
are integral part of high project.
(2) Scientific and Industrial Research [Sec.
80-IA]
100% profit of the
Company registered in India carrying on Scientific and Industrial
Research and Development which is approved by the prescribed authority
at any time before
1.4.1999 is deductible for 5 years.
(3)
Telecommunication [Sec.
80-IA]
100% profit of
undertaking which starts providing Telecommunication service between
1.4.1995 and 31.3.2000 is deductible for initial 5 years and
thereafter 30% is deductible
for another 5 years.
(4) Notified Industrial Park [Sec.
80-IA]
Undertaking which
begins production in a notified Industrial park for the period beginning
1.4.1997 and ending on 31.3.2000 is entitled for 100% deduction of the
profit for initial
5 years and thereafter 30% is deductible for another
5 years.
(5) Refining of mineral oil in North Eastern Region
[Sec. 80-IA]
Undertaking which begins commercial production or refining of
mineral oil in North Eastern
Region or in any part of India on or after
1.4.1997 (in case of refining on or after 1.10.1998) is
entitled for
deduction of 100% of profit for initial 7 years.
(6)
Developing and building Housing Project
[Sec. 80-IA]
Undertaking engaged in
developing and building housing projects approved by a local
authority,
subject to certain conditions, commencing activities on or
after 1.10.1998 and completing the
same by 31.3.2001 is entitled for
deduction at 100% of the profit derived from such business.
(7)
Generation or generation and distribution of
Power [Sec. 80-IA]
Industrial undertaking
engaged in generation or generation and distribution of Power set up in
any part of India which begins to generate power between 1.4.1993 and
31.3.2000 is entitled
for deduction at 100% of profit for initial 5
years and 30% thereafter so that the deduction will
be available for 10
years.
(16)
RATES OF TAXATION UNDER DOUBLE TAXATION AVOIDANCE
AGREEMENTS:
The Central Government, acting under Section 90 of the Income Tax
Act, has been authorized to enterinto Double Tax Avoidance Agreements
(hereinafter referred to as tax treaties) with other countries. The object of such agreements
is to evolve an equitable basis. The agreements allocate jurisdiction
between the source and residence country. Wherever such jurisdiction is
given to both the countries, the agreements prescribe maximum rate of
taxation in the source country, which is generally lower than the rate
of tax under the domestic laws of the country. The double taxation insuch
cases are avoided by the residence country agreeing to give credit for tax
paid in the source country thereby reducing tax payable in the
residence country by the amount of tax paid in the sourcecountry.
RATES OF
TAXATION
|
Sl.No. |
Income Tax Treaty with
(Country) |
Tax Rate |
Fees for technical services |
| Dividend
(%) |
Interest
(%) |
Royalties
(%) |
| (1) |
(2) |
(3) |
(4) |
(5) |
(6) |
| 1 |
Australia |
15(F) |
15 |
(C) |
No Provision |
| 2 |
Austria |
25(F) |
25(E) |
30(G) |
(A) |
| 3 |
Bangladesh |
10 if at least 10%
of the capital of the company paying the dividends is held; 15 in
other cases (F) |
10(B) |
10 |
No
Provision |
| 4 |
Belgium |
15(F) |
15 |
30(G) |
30(G) |
| 5 |
Brazil |
15(F) |
15(B) |
25 for use of trademarks; 15
for others (G) |
No provision |
| 6 |
Belarus |
10-15(F) |
10 |
15 |
15 |
| 7 |
Belgium |
15(F) |
10-15 |
20 |
20 |
| 8 |
Canada
|
15 if at least 10% of the
shares of the company paying the dividends is held; 25 in other
cases (F) |
15(B) |
15-20 |
10 |
| 9 |
Czechoslovakia |
15 if at least 25% of the
shares of the company paying the dividends is held; 25 in other
cases (F) |
15(B) |
30(G) |
30(G) |
| 10 |
Denmark |
15 if at least 10% of the
shares of the company paying the dividends is held; 25 in other
cases (F) |
10 banks
15 others(B) |
20 |
20 |
| 11 |
Finland |
15 if at least 10% of the
shares of the company paying the dividends is held; 25 in other
cases (F) |
15 |
30(G) |
30(G) |
| 12 |
F.R.
Germany |
15(F) |
10 Banks
15 others (B) |
30(G) |
20 |
| 13 |
France
|
15(F) |
10 Banks
15 others |
20 |
20 |
| 14 |
Greece
|
25(F) |
25(E) |
30(G) |
No Provision |
| 15 |
Hungary |
15 if at least 10% of the
shares of the company paying the dividends is held; 25 in other
cases (F) |
15(B) |
40(G) |
20 |
| 16 |
Indonesia |
10 if at least 25% of the
shares of the company paying the dividends is held; 15 in other
cases (F) |
10(B) |
15 |
No Provision |
| 17 |
Israel |
10(F) |
10(F) |
10 |
10 |
| 18 |
Italy
|
25(F) |
15 |
30(G) |
No Provision |
| 19 |
Japan
|
15(F) |
10 Banks
15 others (B) |
20 |
20 |
| 20 |
Kazakstan |
10(F) |
10 |
10 |
10 |
| 21 |
Kenya |
15(F) |
15(B) |
20 |
17.5 |
| 22 |
Libya
|
25(F) |
25(E) |
30(G) |
No Provision |
| 23 |
Malaysia |
25(F) |
25(B)(E) |
30(G) |
No Provision |
| 24 |
Malta
|
10 if 25% shares held;
15 in other cases (F) |
10 |
15 |
15 |
| 25 |
Mauritius |
5 if at least 10% of the
capital of the company paying the dividends is held; 15 in other
cases (F) |
25(B)(E) |
15 |
No Provision |
| 26 |
Nepal |
10 if at least 10% of the
shares of the company paying the dividends is held; 15 in other
cases (F) |
10 Banks
15 others (B) |
15 |
No Provision |
| 27 |
Netherland |
15(F) |
10 Banks
15 others (B) |
20 |
20 |
| 28 |
New
Zealand |
20(F) |
15(B) |
30(G) |
30(G) |
| 29 |
Norway
|
15 if at least 25% of the
capital of the company paying the dividends is held; 25 in other
cases (F) |
15(B) |
30(G) |
20 |
| 30 |
Oman
|
10-12(F) |
10 |
15 |
15 |
| 31 |
People’s Republic of China |
10(F) |
10 |
10 |
10 |
| 32 |
Poland
|
15(F) |
15(B) |
22.5(G) |
22.5(G) |
| 33 |
Romania |
15 if at least 25% of the
shares of the company paying the dividends is held; 20 in other
cases (F) |
15(B) |
22.5(G) |
| | 