Sc, educ. cess and hec on tds u/s 195 and form 16a

TDS on Royalty to foreign cos is now @ 25% wef 01.04.2013. The foreign co does not have any PE in India. 1. What is the criteria for applying SC, Education Cess and HEC on this TDS. 2. Previously this rate was 20%, the foreign company, not being having PAN, would the rate 25% or 20% will apply. 3. How can the foreign company take Tax benefit of this TDS in its own country.