Tax on dividends, royalty and technical service fees in case of foreign companies
(1)
The income-tax payable on the total income of a non-resident being a company) or a foreign company, which includes any income specified column B of the Table below, shall be the aggregate of income-tax specified column C thereof. Table Sl. Income Income-tax No. payable A B C 1. Dividend [other than dividends specified against 20% serial number 2. 2. Dividend received from a unit in an International 10% Financial Services Centre. 3. Interest received from Government or an Indian 20% concern on monies borrowed or debt incurred by Government or the Indian concern in foreign currency not being interest referred to against serial numbers 4 and 5. 4. Interest received from an infrastructure debt fund 5% referred to in Schedule VII (Table: Sl. No. 46). 5. Interest of the nature and extent referred to in section Rates 393(2) (Table: Sl. No. 2), (Table: Sl. No. 3 and 4). specified section (Table: Sl. No. 3 and 4). 6. Distributed income being interest referred to in Rate specified section 393(2) (Table: Sl. No. 6). in section (Table: No. 6). 7. Income received in respect of units, purchased in 20 % foreign currency, of a Mutual Fund specified in Schedule VII (Table: Sl. No. 20 or 21) or of the Unit Trust of India. A B C 8. Total income as reduced by income referred to Income-tax against serial numbers 1 to 7. chargeable such income.
(2)
Where the total income of a non-resident (not being a company) or foreign company, includes any income by way of royalty or fees for 5 services received from Government or an Indian concern in pursuance agreement made after the 31st March,1976, other than income referred to in 59(1), and— (a) the agreement is approved by the Central Government where agreement is with an Indian concern; or (b) where the agreement relates to a matter included in the industrial policy, for the time being in force, of the Government of India, it is as per policy, then, subject to the provisions of sub-section (3), the income-tax payable shall the aggregate of income-tax specified in column C of the Table below:–– Table Sl. Income Income-tax payable No. A B C 1. Royalty [other than income referred to in 20% (1)]. 2. Fees for technical services [other than 20% income referred to in (1)]. 3. Total income as reduced by income Income-tax chargeable referred to against serial numbers 1 and 2. such income. 25