Multinational companies based in the Netherlands, Switzerland, and France may face retrospective tax demands of around ₹11,000 crore on dividend income repatriated from India. This follows a Supreme Court ruling stating that the lower 5% withholding tax on dividend income is not applicable to all OECD countries on a most favoured nation (MFN) basis. The court held that the 5% rate only applies to companies based in countries with which India has a double taxation avoidance agreement (DTAA).