Withholding tax not applicable on interest payable to Company having no PE in India under India-Sweden tax teaty

Re – Idea Cellular Limited, Mumbai – AAR held that the interest payable to Swedish resident on loan guaranteed by specified Swedish corporation is not taxable in India in view of Most Favoured Nation (MFN) clause under India-Sweden tax treaty (tax treaty).

The applicant approached this Authority with the present application seeking an Advance Ruling on a plea that all the agreements relating to this transaction were negotiated and concluded outside India. It takes the stand, that the loan having be

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