Indian High Court Holds Treaty Can Restrict Dividend Distribution Tax on Dividends Paid to UK Resident to 10%

The Bombay High Court (Goa Bench) in a judgement dated 28 November 2025 allowed a tax appeal challenging a Board for Advance Rulings decision that had rejected treaty-rate limitation for Dividend Distribution Tax (DDT) on dividends paid by an Indian company to its UK parent. Historically, India qualified the DDT as a tax on the distributing Indian company rather than a dividend withholding tax borne by the shareholder. Accordingly, the DDT was deemed to be outside the scope of, and unaffected…