{"url":"https://lrlabs.ai/t/trc_form10f_gate","engine":"deterministic","llm_in_path":false,"id":"trc_form10f_gate","question":"What documentation must a non-resident furnish to claim a treaty withholding rate?","answer":"s.159(8), Income-tax Act 2025 (old s.90(4)/(5)) makes treaty relief conditional — \"only when\" — on (a) a tax residency certificate obtained from the government of the residence country, and (b) the prescribed documents and information (the Form 10F lineage, mandatorily e-filed since 1 Oct 2022). The withholding mechanics confirm it: s.393(2) Note 2 applies the agreement rate where the treaty \"applies to the payee\" and the payee \"has furnished a certificate referred to in section 159(8)\". No TRC, no treaty rate — the s.207(2) 20% (plus surcharge and cess) applies.","pinpoint":"s.159(8), Income-tax Act 2025","confidence":"settled","as_at":"14 Aug 2026","quote":"only when— (a) a certificate of his being a resident in any country or specified territory, is obtained by him from the Government of that country","quote_string_verified":true,"quote_source":"provision:IN.ITA2025.S159"}