TDS Under Section 194LC for Interest on ECB paid to Non Resident (PAN Not available)

This query is : Resolved 

Quick Summary
This discussion addresses the TDS rate applicable to External Commercial Borrowings (ECB) interest paid to non-residents when their PAN is unavailable. While Section 194LC typically allows a concessional TDS rate of 5%, the absence of a PAN could lead to a significantly higher TDS rate, potentially up to 20%.

07 April 2025 Respected Sir/Ma'am,

The details are as follows:

1) External Commercial Borrowings Loan Taken before 01-07-2023.
2) TDS as per 194LC 5% concessional rate is applicable.
3) PAN of Non Resident Not Available.

Kindly throw some light on TDS Rate, if Non Resident is not having PAN.

Will still be 5% concessional rate available or TDS should be deducted at Heigher Rate?

Thank You!
Yours Sencierely

07 April 2025 In the absence of a PAN, the withholding tax on interest under Section 194LC could be as high as 20% instead of the standard 5%.

29 September 2025 Good luck..


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