Format pack, 4 formats · FV08-D12

Tax on Cross-border Borrowing, Withholding, Treaty Rates, Thin Capitalisation and Transfer Pricing

What an Indian borrower must work out before paying interest to a non-resident: the withholding rate, the treaty paperwork, the gross-up, the thin capitalisation cap, transfer pricing on associated-enterprise loans, and the treatment of exchange differences. All under the Income-tax Act 2025, with the 1961 Act positions that still apply to legacy loans.

Length
8 pages
Blanks to fill
132
Files
Word and PDF
Law stated to
16 September 2026

The 4 formats inside

  1. 1Withholding determination file note, interest to non-resident lenderITA 2025 ss.393(2), 207, 159, 393(10), 397 · Rule 22058 blanksOn its own₹149
  2. 2Tax, gross-up and FEMA clause bank, loan agreement with non-resident lenderITA 2025 s.393(2), s.393(10) · FEMA Schedule I18 blanksOn its own₹149
  3. 3Thin capitalisation computation working, s.177ITA 2025 s.177 (ex-s.94B)40 blanksOn its own₹149
  4. 4Declaration by non-resident lender, treaty residence, beneficial ownership and no PEITA 2025 ss.159, 393(2), 397(2)25 blanksOn its own₹149

Read the opening

The first part of “Withholding determination file note, interest to non-resident lender”, as it downloads. Blanks are highlighted.

[Name of the firm] file note · Client: [Borrower] · TAN: [Borrower's TAN] · Loan: [LRN / TC ID] · Period: [Period of the interest payment]

1. Facts

Particular

Details

Lender; country of residence; legal form

[____]

Relationship with borrower (AE? related party?)

[____]

Instrument; currency; agreement / issue date

[ECB loan / bond / TC; USD; DD.MM.YYYY]

Interest rate; fees; payment dates; accrual practice

[____]

Who bears Indian tax

[Borrower (gross-up) / Lender]

Use of borrowed funds (India / business outside India)

[____]

9 more paragraphs and tables follow in the full format.

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