CORAA

Tax Residency Certificate (TRC) Working Paper — Sections 90(4) / 90A(4)

Confirms a non-resident payee's TRC and Form 10F are on file before DTAA relief is claimed on a payment — the specific documents Sections 90(4)/90A(4) make a precondition, distinct from the payment itself.

Free · CORAA original — SA-aligned
Updated 28 Jul 2026
Statutory basis
Sections 90(4) / 90A(4), Rule 21AB
Mandatory documents
TRC + Form 10F (where TRC is incomplete per Rule 21AB(1))
Common failure
Expired/wrong-period TRC used for a payment outside its validity
Format
Microsoft Word (.docx)
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Your firm — letterhead
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Used as the letterhead block.
Engagement details
The client and period this document is for.
What’s inside

An excerpt from the template.

TAX RESIDENCY CERTIFICATE (TRC) WORKING PAPER

Payer: ___ · Payee: ___, ___ · DTAA article relied on: ___

Purpose: Sections 90(4) and 90A(4) make furnishing a Tax Residency Certificate obtained from the payee's home-country government a mandatory precondition for that payee to claim DTAA relief — without it, the payee (and, practically, the payer relying on the treaty rate for TDS) cannot avail treaty benefits regardless of actual residence.

A TRC covering the wrong period (e.g. one that expired before the payment date, or one issued for a different financial/calendar year than when the income arose) does not satisfy Section 90(4)/90A(4) for that payment — verify the validity period against the actual date(s) of payment/accrual, not just that a TRC exists somewhere on file.

↑ Excerpt only — the full template is what you download as Word
About this template

What you’re downloading, and when to use it.

This template follows the format published by the Institute of Chartered Accountants of India (ICAI) in the AASB Audit Working Paper Templates (June 2023), the authoritative reference for Indian statutory-audit documentation. Fill in your firm’s letterhead and the engagement details on the form above, click Download Word file, and you’ll get a fully formatted .docx ready to use.

Everything is generated in your browser and on a stateless API endpoint — no account, nothing stored on our servers. We’ll ask for a work email once before your first download so we can send you the file and the occasional relevant update; after that, downloads on this device are instant. Edit freely in Word, Google Docs or Pages before sending to your client.

Common questions

FAQs.

Is a TRC alone always sufficient, or is Form 10F also required?
Form 10F is required in addition to the TRC whenever the TRC itself does not already contain all the particulars prescribed under Rule 21AB(1) — nationality/status, tax identification number, period of residence, and address, among others. Many foreign tax authorities' standard TRC formats omit one or more of these, making Form 10F a near-universal practical requirement even though it is technically conditional.
What happens if a payer applies the DTAA rate without a valid TRC on file?
The payer bears the TDS risk — if a TRC/Form 10F is not on file for the relevant payment, the deducting officer or a later assessment can treat the treaty-rate deduction as unsupported and raise a shortfall demand for the difference between the domestic rate and the treaty rate actually applied, along with interest.
Does the TRC need to be renewed every year?
Yes, practically — a TRC is issued for a stated validity period (commonly the payee's home-country tax/calendar year), and a fresh TRC covering the period in which the relevant payment falls should be obtained and placed on file before relying on it again for a subsequent year's payments.
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