Executive summaryThe Indian Tax Tribunal1 ruled on 30 April 2021 that tax on dividend income earned by a nonresident shareholder during the dividend distribution tax (DDT) regime must be limited to the applicable in-force tax treaty rate. The Tribunal ruled that dividend income was subject to tax in the hands of shareholders even during the DDT regime, as the imposition of tax was merely shifted to the company distributing the dividends for administrative convenience, and therefore, the tax treaty rate takes precedence over the domestic DDT rate.The Indian tax law was amended with effect from 1 April 2020 to abolish the...