Tds on royalty u/s 195

This query is : Resolved 

11 November 2013 Dear Experts,

we are a Public limited company and we are paying royalty for technical assistance from Some of the Japan and Spain based companies for which we are paying certain %age of sales amount as royalty.

kindly let me know currently applicable rate of TDS for following

Japnies Company-

PAN Available for party
Pan not available for party

Spainsh Company

PAN Available for party
PAN not available for party


Thank you in advance.


11 November 2013 Japan: if PAN available : 10% under Article 12 of the DTAA. If not, then 20%

Spain: 20% in both cases (Article 13(2)(ii).


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