10 May 2013
please read my article on this subject.
If payment is not covered under DTAA, then section 206AA applies.
However, if the prevailing withholding tax rate in India is equals to or exceeds 20%, then no significance of PAN arises as u/s. 206AA MINIMUM rate is 20%.
If payment is covered under FTS "fees for technical services" the minimum WT rate is 25%. thus in this case, no need to apply for PAN if tax impact in normal case exceeds 20%.
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