Dear Friends,
As per the amendment of Sec. 90 a Non-Resident cannot claim the benefit of DTAA unless he has a Tax Residency Certificate of the foreign Country. In our case we have a client who is a Resident and has investment Income in Singapore. As per the DTAA with India -Singapore investment income is chargeable @ 15% in India.Will the same status quo continue?????
DTAA requires Resident to be a beneficial owner to apply 15% rate. Beneficial ownership can be proved only using TRC.
However the amendment referred to u/s 90(3) is w.e.f 01-04-2013.
SMJ global advisors pvt ltd
New Delhi
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T R SOOD & CO
New Delhi
CA Inter
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