Examples of Tax Residence Certificate in a sentence
On this basis the Subsidiary should continue to be entitled to certain reliefs from Indian tax under the Mauritius/India Tax Treaty (see ‘India’ Taxation above).As from 1 January 2015, there are new substance requirements to obtain a Tax Residence Certificate (TRC).
The Bidder should provide the latest declaration of Permanent Establishment in India at time of service invoice, PAN No.in India, Tax Residence Certificate from respective country of Government for the purpose of Form 15CB from tax consultant.
Where a person wishes to be certified as a resident in Mauritius in respect of an income year, he should apply to the Director-General for a Tax Residence Certificate.
Unless it is a case where Circular 789 relating Tax Residence Certificate in the case of Mauritius, orLimitation of Benefits clause in India-Singapore treaty is applicable, the Revenue may invoke GAAR and consequently deny treaty benefit.Example -12:Facts: An Indian company, X Ltd., is a closely held company and it is a subsidiary of company Y Ltd.
Any non-resident Equity Shareholder claiming benefit under any DTAA between India and any other foreign country should furnish the Tax Residence Certificate (“TRC”) provided to him/it by the income tax authority of such other foreign country of which he/it claims to be a tax resident, which has been inserted as a mandatory requirement by the Finance Act, 2012.
Until the abolition of the tax on transfer of listed securities, Circular 789 of 2000 accepting Tax Residence Certificate (TRC) issued by the Mauritius authorities may be retained.
In the absence of such Tax Residence Certificate, the Acquirer and/or the PAC will arrange to deduct tax in accordance with the provisions of the Income Tax Act and without having regard to provisions of any DTAA.
Unless it is a case where Circular 789 relating Tax Residence Certificate in the case of Mauritius, or Limitation of Benefits clause in India-Singapore treaty is applicable, the Revenue may invoke GAAR and consequently deny treaty benefit.
Until the abolition of the tax on transfer of listed securities, the Circular 789 of 2000 accepting Tax Residence Certificate (TRC) issued by the Mauritius authorities may be retained.
The Tax Residence Certificate under subsection (2) shall be issued within a period of 7 days from the date of the application, provided that the person has submitted the return required to be submitted under section 112 or 116, as the case may be, and paid such service fee as may be prescribed.