I understand that if we provide this Certificate of Residence to India Tax Office, the taxing right will be in Thailand.
Meaning that Gov’t of India has no right to withhold any taxes. Thus, you have to pay commission 100% without any deduction. On the other hand, if without such COR, taxing right will be in the Gov’t of India. So you have to pay commission by 20% tax deduction. Sojitz Thailand will receive only 80%. That’s refer to the DTA (Article 7) between Gov’t of India and Thailand.