Friday, 2 February 2024

Payments made to a foreign Entity

 

 

1.     Section 195 of the Income Tax Act pertains to the deduction of tax at source (TDS) on payments made to non-residents (including foreign companies) in India. It outlines the obligations of the person responsible for making the payment to deduct tax and remit it to the Indian government

 

2.     As per section 206AA Where any person is entitled to receive any income on which tax is deductible at source, he is required to furnish his PAN to the diductor. In case the PAN is not furnished, the tax shall be deducted at a higher rates.

 

3.      As per Section 206AA, if the recipient fails to furnish his PAN to the diductor then

tax shall be deducted at the higher of the following rates:

(a) At the rate specified in the relevant provision

(b) At the rate or rates in force

(c) At the rate of 20% 

 

4.     Further where the deductee is a non-resident, the provision of section 206AA shall not be applicable in certain transactions.

 

5.     On specified income - By virtue of Rule 37BC, a diductee, being a non-resident person

(including a foreign company), is not required to furnish his PAN to the deductor if he receives the following income:

a) Interest

(b) Royalty

(c) Fees for technical services

(d) Dividend

(e) Payments for transfer of any capital asset.

 

6.     If the payment does not fall under the above category then check

1.      Whether the vendor have a PE in India, if so  a with holding tax @40%  should be deducted while making the payment.

2.     If vendor has no PE in India then check for the following :

a.     PAN

b.    Valid TRC

c.     Form 10F

3.       If any one of the above documents has been furnished by the Diductee then, No withholding tax is required to be deducted.

 

4.        If the deductee could not furnish any of the specified documents, a withholding tax @20% is required to be deducted as per sec 206AA.

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