Salary- DTAA

[MANOHAR KALBURGI]

Dear Sir,

The Indian private company pays salary to Singapore based resident as a salary which is paid in Singapore Dollar only.

Since such salary liable for TDS u/s 192 for NRI also and the question involved here, is this payment is governed by which Article if DTAA (IND & Singapore) taken into account. And to take the beneficial of which ever is lower.

Thanks in Advance.

AI Summary

Taxation of cross border salary: determine whether domestic withholding or DTAA employment article governs tax treatment and relief.
Whether salary paid by an Indian private company to a Singapore resident in Singapore dollars is subject to Indian withholding under domestic salary provisions and which DTAA article governs the taxation of that employment income for claiming the lower or beneficial treatment.