TDS on distributed income by business trusts: payers must deduct tax at specified rates on distributions to unit holders. Section 194LBA requires payers to deduct tax at source on distributed income from business trusts at the time of credit or payment. Residents are subject to deduction at ten per cent; non-resident unit holders and foreign companies face withholding at specified rates including five per cent for certain categories and ten per cent for others. Sub-section (2A) exempts application for income of the sub-clause (b) variety where the special purpose vehicle has not opted under section 115BAA. Payments of the type in clause (23FCA) to non-residents are taxable at rates in force.