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tds on membership payment in foreign currenty

This query is : Resolved 
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(Querist)
23 June 2010 Dear Sir,
We have company, and now we would like to make payment in us dollar as annual membership fees of our director. Now my query is whether we have to deduct tds from such payment. The corporation to whom we have to make pmt does not have any pe in india and for the same we have acquired declaration also. we have require 15CA & 15CB to remit the same.

Kindly help
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Shudhanshu Agrawal

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Shudhanshu Agrawal (Expert)
23 June 2010 As per Section 9 the payment will be considered to be accrue and arise in India and hence taxable in India. As the company does not have any PE in India so Section 195 will be applicable for TDS deduction.
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