Withholding Tax
This query is : Resolved
18 January 2011
Dear Professional colleague,
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.
Regards,
Piyush Jain
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.
Regards,
Piyush Jain
19 January 2011
India -registered Office Country Treaty.
Yes 20% shall be deductible.
Yes 20% shall be deductible.
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