#GTBharat's PolicyCast Episode 18 | Dividend distribution tax and treaty relief with Riaz Thingna

How does the recent Bombay High Court ruling on Dividend Distribution Tax (DDT) reshape India’s international tax landscape?

In the latest episode of #GTBharat’s PolicyCast, Riaz Thingna, Partner, Tax, decodes the landmark judgment capping the DDT rate in line with the India–UK tax treaty, reversing the positions taken by the BAR and ITAT Special Bench decision.

Riaz shares insights on:

• Why treaty provisions prevail over domestic law

• The Court’s interpretation of DDT as a tax on shareholder income

• Evaluation of past position and potential refund claims

• Practical challenges, including gross-up, refunds, and foreign tax credit claims

• What taxpayers should monitor till the matter attains finality before the Supreme Court

#PolicyCast #InternationalTax #CrossBorderTaxation #CorporateTax #Podcast