Non-resident payment taxability determinations allow certificates limiting withholding to the chargeable proportion after statutory and treaty examination.

Rule 214 permits a payer to apply in Form No. 129 for determination of the proportion of a payment to a non-resident that is chargeable to tax. The Assessing Officer examines taxability under the Income-tax Act, 2025 and the relevant Double Taxation Avoidance Agreement, where applicable, and may issue a certificate for deduction on the taxable proportion. The certificate is limited to the named non-resident and specified tax-year period, may be cancelled before expiry, and may be renewed through a fresh application.

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