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TDS on Foreign Payments: Section 195 & DTAA | NumberIQ

CA Sitaram PareekLast reviewed June 20266 min read

When paying a non-resident a sum taxable in India, deduct TDS under Section 195 at the more beneficial of the Income-tax Act rate or the applicable DTAA rate. The treaty rate needs a Tax Residency Certificate and Form 10F; most remittances require a CA's Form 15CB and the remitter's Form 15CA before payment.

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Income-tax Act 2025 update: Section 195 of the 1961 Act is now Section 393(2) under the new Income-tax Act 2025, effective 1 April 2026. Rates and thresholds discussed below remain applicable unless stated.

The decision: Act rate or treaty rate

For each foreign payment, first decide if it is chargeable to tax in India. If yes, apply the lower of the Act rate or the relevant DTAA article rate. To use the treaty rate, obtain from the payee a Tax Residency Certificate (TRC), Form 10F, and (where relevant) a no-PE declaration. Without PAN, Section 206AA can force a higher rate (subject to Rule 37BC relief for certain payments).

The 15CA/15CB drill

  1. Determine taxability and the rate (Act vs treaty).
  2. Obtain Form 15CB — a CA's certificate on taxability and rate — for most taxable remittances above the threshold.
  3. File Form 15CA online (Part A/B/C/D as applicable).
  4. Remit through the AD bank with the forms.

Payments in the Rule 37BB specified list are exempt from 15CA/15CB.

Grossing up

If the contract is net of tax (the payee is to receive a fixed amount), the income is grossed up under Section 195A so the payer bears the TDS. For example, a net royalty of Rs.90 at a 10% treaty rate grosses up to Rs.100, with Rs.10 TDS.

Practical points

Key takeaways

  • 195: deduct at the more beneficial of the Act or DTAA rate.
  • Treaty rate needs TRC + Form 10F (+ no-PE declaration).
  • Form 15CB (CA) + 15CA (declaration) before remittance.
  • Net-of-tax contracts are grossed up under Section 195A.

Frequently Asked Questions

What rate of TDS applies on a payment to a non-resident?

The more beneficial of the Income-tax Act rate or the applicable DTAA rate, provided the payee furnishes a TRC, Form 10F and, where relevant, a no-PE declaration.

Are Form 15CA and 15CB always needed?

Most taxable foreign remittances above the threshold need them, but the specified list of payments under Rule 37BB is exempt.

What is grossing up under Section 195A?

Where a contract is net of tax, the income is grossed up so the TDS is borne by the payer, increasing the base on which tax is computed.

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Written & reviewed by

CA Sitaram Pareek

Chartered Accountant (ICAI) and holder of the Diploma in International Taxation (DIIT-ICAI). Works in-house with a multinational group operating across India, the UAE and Singapore, handling GST compliance, direct tax, transfer pricing, DTAA advisory and FEMA matters. Every article on NumberIQ is written against the bare Act, current CBDT/CBIC notifications and official portals (incometax.gov.in, gst.gov.in, cbic.gov.in).

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