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trIs it necessary to reapply for DTA-03 approval for subsequent payments after obtaining the initial approval?
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Is it necessary to reapply for DTA-03 approval for subsequent payments after obtaining the initial approval?
The State Tax Service has clarified that an approval letter issued based on a DTA-03 application is valid only for the invoice amount and payment period specified in the application. Therefore, if the payment amount exceeds the approved amount or a new payment period arises, a new DTA-03 application must be submitted for the additional amount or the new payment period.
At the same time, if the exact amount of payments planned under the contract during the year is not known in advance, a DTA-03 application may be submitted based on the non-resident's tax residency certificate, indicating an estimated total amount. In such cases, the payment period may be determined until the end of the current year or, where permitted by law, until the end of the following year.
The authority also noted that if the amount stated in the actual invoices issued later exceeds the amount or payment period approved in the approval letter, a new DTA-03 application must be submitted for the excess amount or the additional period. This approach is intended to ensure the proper application of international agreements on the avoidance of double taxation.
The State Tax Service has clarified that an approval letter issued based on a DTA-03 application is valid only for the invoice amount and payment period specified in the application. Therefore, if the payment amount exceeds the approved amount or a new payment period arises, a new DTA-03 application must be submitted for the additional amount or the new payment period.
At the same time, if the exact amount of payments planned under the contract during the year is not known in advance, a DTA-03 application may be submitted based on the non-resident's tax residency certificate, indicating an estimated total amount. In such cases, the payment period may be determined until the end of the current year or, where permitted by law, until the end of the following year.
The authority also noted that if the amount stated in the actual invoices issued later exceeds the amount or payment period approved in the approval letter, a new DTA-03 application must be submitted for the excess amount or the additional period. This approach is intended to ensure the proper application of international agreements on the avoidance of double taxation.