DTAA under locan Gurantee Services, Income Tax

[MITSUI PRIME]

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 Companies 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

please provide your valuable advice.

 Regards

Arjun Sachdeva

Posts / Replies

[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.