My client has arranged foreign currency loan from foreign bank branch situated in one country and bank is incorporated in different country.
Now as interest is to be paid and withholding tax to be deducted, please guide which DTAA treaty will be used India-Branch Country treaty or India-Registered Office country treaty.
As the bank does not have PAN,will TDS will be deducted @20% overriding the treaty provisions.
CAclubindia
