DTAA under locan Gurantee Services

[MITSUI PRIME ADVANCED]

Dear Sir,

We have involved in foreign payment under Loan Guarantee Fee Loan is provided by JABIC( Japans Association of Borrowing Corporation) We have paid installment to Mitsui Chemical Inc., Japan. We have registered under Companies Act, 1956, with name of Mitsui Prime Advanced Composites India Pvt India . MPAC, India paid Installment against loan to MCI, Japan ,

in this above scenario   attract Double Taxation Avoidance Agreement between India and Japan

TDS is deductible under DTAA on loan guarantee Services

please provide your valuable advice.

 Regards

Arjun Sachdeva

AI Summary

Indian Company Seeks Clarity on TDS Applicability for Loan Guarantee Fees under India-Japan DTAA, Citing Section 195. A company registered in India, involved in foreign payments for a loan guarantee fee to a Japanese entity, is inquiring about the applicability of the Double Taxation Avoidance Agreement (DTAA) between India and Japan. They seek advice on whether Tax Deducted at Source (TDS) is applicable under the DTAA for these transactions. The response suggests that TDS may be required according to Section 195 and related provisions, but a detailed examination of the facts and law is necessary for a definitive conclusion.