Thursday , April 25, 2024 |   17:35:27 IST
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
About Us Contact Us Newsletters
 
NEWS FLASH
 
Transformative policies needed to manage risks of new emerging technologies (See 'Brief') I-T- DRP has no power to set-aside the issue to AO: ITAT (See 'Breaking News') I-T- DTAA does not get triggered at all when a domestic company pays DDT u/s 115-O of the Act : ITAT (See 'Breaking News') TP - Arm's length computation of corporate guarantees issued by assessee in favour of its AEs abroad taken at 1% which has been approved for earlier A.Ys, cannot be disturbed in absence of contrary: ITAT (See 'Breaking News') TP - Adjustment made to interest rate by treating Letter of Credit as bank guarantee cannot be accepted: ITAT (See 'Breaking News') I-T-The commission income earned by foreign agents cannot be termed to have incurred or arisen in India, and therefore, is not taxable in India: ITAT (See 'Breaking News') TP- AO does not have the jurisdiction to propose any transfer pricing adjustment in case where he has not made any reference to the TPO: ITAT (See 'Breaking News') TP - Letter of comfort issued by assessee in respect of credit facility extended to its AEs by banks outside India, which was admitted as liability having bearing on assets, constitutes international transaction: ITAT (See 'Breaking News') DTAA - Payment made to UAE entities cannot be deemed to be Fees for Technical Service, where no technical knowledge, know-how or skill is made available: ITAT (See 'Breaking News') DTAA - Payments made from India to UAE are not taxable in India, where UAE-based recipient company has no PE in India, as mandated under India - UAE DTAA: ITAT (See 'Breaking News') DTAA - Payment received on account of subscription, professional and training services cannot be deemed to be Fees for Technical service and be taxed as Royalty, where no technical know-how is made available: ITAT (See 'Breaking News') I-T- Onus of establishing receipt of services from Associated Enterprise has to be discharged on year to year basis by assessee company: ITAT (See 'Breaking News') I-T - If assessee is not making available underlying know-how with respect to research projects as enumerated under DTAA & MOU, then receipts under head ILP membership cannot be reckoned as FIS: ITAT (See 'Breaking News')
 
TII SEARCH
 
 
   
Home >> News Brief
 

TDS u/s 196A - Tax Treaty benefits to be allowed
By TII News Service
Feb 01, 2023 , New Delhi

    

NEW DELHI, FEB 01, 2023: SECTION 196A of the Act provides for TDS on payment of certain income to a non-resident (not being a company) or to a foreign company, at the rate of 20%. The income is required to be in respect of units of a Mutual Fund specified under clause (23D) of section 10 of the Act or from the specified company referred to in the Explanation to clause (35) of section 10 of the Act.

Representations have been received requesting that the benefit of tax treaty may be considered at the time of TDS so that if the treaty provides a rate lower than 20%, TDS is made at that lower rate.

In order to provide the relief requested by taxpayers, it is proposed to insert a proviso to sub-section (1) of section 196A of the Act. This proviso seeks to provide that the TDS would be at the rate which is lower of the rate of 20% and the rate or rates provided in agreement referred to in sub-section (1) of section 90 or sub-section (1) of section 90A of the Act, in case of a payee to whom such agreement applies and such payee has furnished the tax residency certificate referred to in sub-section (4) of section 90 or sub-section (4) of section 90A of the Act.

This amendment will take effect from 1st April, 2023.

 
 
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI TII
  • DTAA
  • Circulars (I-T Act, 1922)
  • Limited Treaties
  • Other Treaties
  • TIEAs
  • Notifications
  • Circulars
  • Relevant Sections of I-T Rules,1962
  • Instructions
  • Administrative Orders
  • DRP Panel
  • I-T Act, 1961
  • MLI
  • Relevant Portion of I-T Act,1922
  • GAAR
  • MAP
  • OECD Conventions
  • Draft Guidelines
  • DTC Bill
  • Committee Reports
  • FATCA
  • Intl-Taxation
  • Finance Acts
  • Manual on EoI
  • UN Model Taxation
  • Miscellaneous
  • Cost Inflation Index
  • Union Budget
  • Information Security Guidelines
  • APA Annual Report
  • APA Rules
  • Miscellaneous
  • Relevant Sections of Act
  • Instructions
  • Circulars
  • Notifications
  • Draft Notifications
  • Forms
  • TP Rules
  • APA FAQ
  • UN Manual on TP
  • Safe Harbour Rules
  • US Transfer Pricing
  • FEMA Act
  • Exchange Manual
  • Fema Notifications
  • Master Circulars
  • Press Notes
  • Rules
  • FDI Circulars
  • RBI Circulars
  • Reports
  • FDI Approved
  • RBI Other Notifications
  • FIPB Review
  • FEO Act
  • INTELLECTUAL PROPERTY
  • CBR Act
  • NBFC Report
  • Black Money Act
  • PMLA Instruction
  • PMLA Bill
  • FM Budget Speeches
  • Multimodal Transportation
  • Vienna Convention
  • EXIM Bank LoC
  • Manufacturing Policy
  • FTDR Act, 1992
  • White Paper on Black Money
  • Posting Policy
  • PMLA Cases
  • Transfer of Property
  • MCA Circular
  • Limitation Act
  • Type of Visa
  • SSAs
  • EPFO
  • Acts
  • FAQs
  • Rules
  • Guidelines
  • Tourist Visa
  • Notifications
  • Arbitration
  • Model Text
  • Agreements
  • Relevant Portion of I-T Act
  • I-T Rules, 1962
  • Circulars
  • MISC
  • Notification
  • About Us
  • Contact Us
  •  
     
    A Taxindiaonline Website. Copyright © 2010-2023 | Privacy Policy | Taxindiainternational.com Pvt. Ltd. OPC All rights reserved.