With the Budget 2020-21 levying dividend distribution tax (DDT) in the hands of recipients, the Reliance Industries-Brookfield infrastructure investment trust, Tower Infrastructure Trust, is looking at the option of raising more debt from foreign and ultra-high net-worth investors and offer attractive interest to them.
These investors will be able to save on tax by investing via jurisdictions which have lower withholding tax rates on debt instruments. While some tax-treaty countries, such as Singapore, have a withholding tax rate of 15 per cent, there are a few jurisdictions where the withholding tax rate on a debt instrument is as low as 7.5