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Under DTAA india and japan, Income Tax

Issue Id: - 5248
Dated: 29-1-2013
By:- MITSUI PRIME

Under DTAA india and japan


  • Contents

Dear Sir,

We have involved in foreign payment under Loan Guarantee Fee Loan is provided by JABIC( Japans Association of Borrowing Corporation) We have paid installment to Mitsui Chemical Inc. , Japan . We have registered under Company act 1956 with name of Mitsui Prime Advanced Composites India Pvt India . MPAC, India paid Installment against loan to MCI, Japan , in this above scenario attract Double Taxation Avoidance Agreement between India and Japan TDS is deductible under DTAA on loan guarantee Services ?

under Artical 12 or artical 22 

TDS rate 10% 

or in this case locan sentancy not in teratry than applay 40% TAX in the case of fourign Compnay?

 please provide your valuable advice.

Regards

Arjun Sachdeva

Posts / Replies

Showing Replies 1 to 1 of 1 Records

Page: 1


1 Dated: 21-3-2015
By:- Rama Krishana

The payment made to Mitsui Chemical Inc., Japan. if liable to TDS as per the provisions of Section 195 read with Section 9 and DTAA and any other related provisions, you need to deduct TDS. But, I think it requires detail and indepth examination of facts and law.


Page: 1

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