Unlock value of Tax Residency Certificate (TRC) in non-resident payments. Explore its crucial role in efficient and compliant cross-border transactions.
Answer:
S. 90(4) – NR cannot avail benefit under Treaty without Tax Residency Certificate (TRC).
S. 90(5) – The assessee has to provide such other details as may be prescribed.
Rule 21AB – specifies the information to be provided in Form 10F – if the same are not covered in the TRC. So, TRC and Form 10F go together. Form 10F alone not enough.
Answer:
If special conditions are specifying contrary in DTA – like Beneficial ownership, Limitation of Benefits clause – TRC is not enough.
Answer:
Practical decision can be taken based on past facts after due diligence. Once the TRC is obtained, the treaty benefit would be available for the whole year.
Answer:
The remitter can only rely on the TRC for the period during which the income is earned.
Answer:
As DTAA provisions are not exercised, provisions of Sections 90(4), 90(5) and the relevant rules will also not be applicable.
Understand the GST appeal procedure for 2025. Learn about filing, time limits, demand order appeals, the GST portal & taxpayer rights.
Understand GST Audit under Section 65 of the CGST Act. Ensure compliance with provisions, timelines, and documentation. Learn about audit process.
Navigate GST adjudication successfully! Understand the GST law, show cause notice, time limits, and provisions for representing your case effectively.
