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< On the letterhead of the Foreign Company >

Date: [•]

To,

[•Name and address of the Indian Party],

Re: Declaration of no permanent establishment for the period 01 April 2022 to 31 March 2023

We hereby certify that,

1. [•Name of Foreign Company] (the Company) is a company incorporated on [•]


2. The Company is a tax resident of [•] as per the tax laws of [•]
3. The Company does not have and is not likely to have a permanent establishment in India as
defined in Article 5 of India- Netherlands Double Taxation Avoidance Agreement (India-
Netherlands tax treaty)

This certificate is being issued to [•Name of Indian Party] to enable them to decide upon the
withholding tax applicable on the transaction with our company.

For [•Name of Foreign Company]

Authorised Signatory

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