Withholding tax

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KALYANA SUNDARAM.T.V. (Querist)
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28 March 2012 My company is going to ECB loan amounting to 35M under automatic route. And we will have to pay up-front fess to singapore banker and guarantee insurance premium to korea insurance firm.

In this regard please clarify what is the withholding tax applicable on

1. Up front fees payable in USD to singapore bank.
2. Insurance premium amount payable to korea insurance company.

For your information india is having DTAT with both the countries.

Arihanth Jain

Arihanth Jain (Expert)
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28 March 2012 In my view, Tds shall be nil in both cases assuming the recipients have PAN in India. No PAN will attract 20% Tds u/s 206AA.

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