Article 10 - Dividends
Dividends paid by a company resident in one State to a resident of the other State may be taxed in the recipient's State of residence, but the source State retains a primary withholding right at the treaty rate.
Under the India-Turkey DTAA, the withholding tax on dividends is 15%. 15%. The source-State rate caps the withholding only where the beneficial owner is a resident of the other State. The treaty rate operates as a ceiling - India's domestic withholding may be lower, in which case the lower rate applies.
Practical compliance: To claim the treaty rate, the recipient must provide the Indian payer with (a) a Tax Residency Certificate (TRC) from the home tax authority, (b) Form 10F filed electronically with the Indian Income Tax portal, and (c) a self-declaration of beneficial ownership. Without these, India applies the domestic rate (typically 20% for non-residents on dividends).