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Section 90 (4) of the Income Tax Act has been made it mandatory for a non-resident who wishes to avail Treaty benefits to provide Tax Residency Certificate (TRC) to the Indian Company (the Tax deductor). ... Rule 21AB of the Income-tax Rules prescribes that the TRC must contain the information specified in Form 10F.

From this logic, the concept of Permanent Establishment (PE) is derived. Article 5 on Double Tax Avoidance Agreements (DTAA) that India has signed with various countries thus defines the term PE as "A Fixed place of business through which the business of an enterprise is wholly or partly carried on."

Form 10F must be verified by the government of the country in which the assessee is a resident for the period applicable. It is a declaration that the assessee resided in the foreign country which is covered under a DTAA with India and hence, the tax rate applicable to the income is at the rate mentioned in the DTAA.

Tax Residency Certificate (TRC) For Indian Resident Assessee 2013 the India Residents who earns Income from Countries with which India have a DTAA can obtain a Tax Residency Certificate from Income Tax Department.

To obtain Form 6166, a letter of U.S. Residency Certification, you must submit a completed Form 8802, Application for United States Residency Certification. A user fee is charged to process all Forms 8802.

United States: The I.R.S. Approach To Dependent Agent Status. ... In general, the permanent establishment ("P.E.") article of a treaty between the foreign taxpayer's jurisdiction and the U.S. will govern U.S. tax treatment of the foreign taxpayer's U.S. activities, if the taxpayer is eligible and elects for treaty benefits ...

A permanent establishment (PE) is a fixed place of business which generally gives rise to income or value-added tax liability in a particular jurisdiction. The term is defined in many income tax treaties and in most European Union Value Added Tax systems.

Tax Residency Certificate (TRC) For Indian Resident Assessee 2013 the India Residents who earns Income from Countries with which India have a DTAA can obtain a Tax Residency Certificate from Income Tax Department.

Broadly speaking, a Service permanent establishment ( P.E. ) is an international tax concept under which services provided by a nonresident may give rise to a P.E. in the source country if the services are provided beyond a certain period of time.