1. s/115BBD allows lower tax rate @15% on Fgn divid without any deduction or allowance. The legislative intent was to tax at lower rate

2. Now with domestic dvid taxable @ slab rate after allowing interest deduction and 80M deduction, 115BBD may not be beneficial

3. Whether non allowable interest exp (I.e above 20% of dividend) can be considered as cost of acquisition is open issue

4. Tax Withholding burden on companies is increased with different TDS rate for variety of investors including foreign investor of different countries

5. 20% deduction of interest whether on gross dividend or on net dividend after deduction of 80M
 
6. Multiple tax rates and TDS compliance may lead buy back option viable

7. 80M is silent on distribution of foreign dividend to shareholder

8. Now challenge could be in substantiating beneficial ownership and commercial substance to take treaty beneficial divid tax rate

9. With dividend being taxable – expenses incurred is restricted to interest (20%of divid) now excess expenses which are claimed by 14A rule might be questionable