Withholding on FII securities income applies to every payment, with lower treaty rates available upon prescribed certification.

Tax must be deducted at source on income from securities referred to in section 210(1) when paid or credited to a Foreign Institutional Investor. Any person making the payment is responsible for deduction at the earlier of credit or payment, and no monetary threshold applies. The default rate is 20%, but a lower rate under an agreement referred to in section 159 may apply if the FII is eligible and furnishes the prescribed certificate.

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