Tds in absence of pan
This query is : Open
02 January 2012
I have to make payment to Citi Bank, Singpore which is a wholy owned subsidiary of Citi Bank, New York.
Rate as per DTAA is 10%
However the Bank has given me PAN of Citi Bank, India.
Whether it is sufficient to have PAN of Citi Bank, India for compliance of Section 206AA or I need to deduct Tax @ 20%.
It is but obvious that every subsidiary of Citi Bank can't obtained PAN in every country of the world.
Please suggest from Client's point of view as the burden of TDS in on Client.
Rate as per DTAA is 10%
However the Bank has given me PAN of Citi Bank, India.
Whether it is sufficient to have PAN of Citi Bank, India for compliance of Section 206AA or I need to deduct Tax @ 20%.
It is but obvious that every subsidiary of Citi Bank can't obtained PAN in every country of the world.
Please suggest from Client's point of view as the burden of TDS in on Client.
02 January 2012
Deduct the TDS @ 10% IN YOUR CASE,
HAS COMPANY PAID THE INTEREST ON BUYERS CREDIT?
HAS COMPANY PAID THE INTEREST ON BUYERS CREDIT?
Message likes :
1 times
02 January 2012
Yes. Co. is paying Interest to Bank on Buyer's Credit.
02 January 2012
Yes. Co. is paying Interest to Bank on Buyer's Credit.
02 January 2012
Yes. Co. is paying Interest to Bank on Buyer's Credit.
02 January 2012
Yes. Co. is paying Interest to Bank on Buyer's Credit.
02 January 2012
Ok. Deduct the tds @10% on gross amount and obtained the form 15CB from CA
02 January 2012
But the councel is insisting on PAN of Citi Bank Singapore otherwise, he will apply 206AA and issue 15CB with a TDS of 20%.
02 January 2012
But the councel is insisting on PAN of Citi Bank Singapore otherwise, he will apply 206AA and issue 15CB with a TDS of 20%.
02 January 2012
in same case we also deduct tds @ 10%
03 January 2012
Thank You CA Navin Jain.
Any other expert opinion!!!!!!
Any other expert opinion!!!!!!
03 January 2012
Here the issue is that Citibank Singapore and New Delhi Branch are the part of Citibank, New York and for the purpose of DTAA, India-USA and not India-Singapore DTAA shall be relevant.
THE PAN of Citibank India represents PAN of Citibank New York and that shall suffice the purpose of sec. 206AA however kindly take in writing from Citibank India that Citibank India was not involved in the loan transaction between Citibank Singapore and Indian party and no part of interest income payable to Citibank Singapore is attributable to Citibank India.
Anuj
+91-9810106211
femaquery@gmail.com
THE PAN of Citibank India represents PAN of Citibank New York and that shall suffice the purpose of sec. 206AA however kindly take in writing from Citibank India that Citibank India was not involved in the loan transaction between Citibank Singapore and Indian party and no part of interest income payable to Citibank Singapore is attributable to Citibank India.
Anuj
+91-9810106211
femaquery@gmail.com
04 January 2012
Thanx a lot sir
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