DDT vs DTAA: Can Dividend Distribution Tax on Companies Be Reduced Using Treaty Rates? Bombay High Court Says No

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DDT vs DTAA: Can Dividend Distribution Tax on Companies Be Reduced Using Treaty Rates? Bombay High Court Says No

Direct Tax

Published on

28/04/2026

By Mariya Paliwala

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The Bombay High Court has delivered a significant ruling clarifying the legal position on whether Dividend Distribution Tax (DDT) can be reduced by invoking concessional rates under Double Taxation Avoidance Agreements (DTAAs). The bench of Justice G. S. Kulkarni and Justice Aarti Sathe observed that DDT, being a tax on the company’s distributed profits, cannot…

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Mariya Paliwala https://www.jurishour.in/

Mariya is the Senior Editor at Juris Hour. She has 7+ years of experience on covering tax litigation stories from the Supreme Court, High Courts and various tribunals including CESTAT, ITAT, NCLAT, NCLT, etc. Mariya graduated from MLSU Law College, Udaipur (Raj.) with B.A.LL.B. and also holds an LL.M. She started her career as a freelance tax reporter in the leading online legal news companies.

DDT vs DTAA: Can Dividend Distribution Tax on Companies Be Reduced Using Treaty Rates? Bombay High Court Says No

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