PAN Card Rules Changed: Form 96 Mandatory for NRIs, Foreign Entities Under Income Tax Act 2025: Know Details
The Income Tax Department has introduced tighter and more structured PAN (Permanent Account Number) rules for non-resident individuals, NRIs, and foreign entities operating in India under the Income Tax Act, 2025. The updated framework, which will come into effect from April 2026.
Income Tax Department Tightens PAN Rules for NRIs, Foreign Firms Under New Income Tax Law 2025
As part of the changes, the government has replaced older PAN application forms with a new category-based system numbered 93 to 96. From April 2026, Form 96 will become mandatory for foreign entities and non-resident applicants, replacing the existing Form 49AA. Officials say the new structure is designed to improve transparency and make taxpayer classification more accurate.

Foreign Companies Required to Submit TIN and Address Proof Under New PAN Rules
Under the revised rules, foreign companies applying for a PAN in India will now have to provide additional documentation. This includes their Tax Identification Number (TIN) or equivalent registration number from their home country, along with proof of incorporation and address details. The objective is to better link foreign business identities with their Indian financial records.
Foreign individuals connected to these entities will also face stricter disclosure requirements. They will now be required to provide their TIN or similar tax identification from their country of residence while applying for a PAN in India. This step is intended to help tax authorities better monitor international financial transactions.
Stricter PAN Norms for NRIs and Foreign Firms Include Mandatory Local Representative Requirement
Another major change under the new rules is the requirement for foreign entities to appoint an Indian-based authorised representative. This person must have a valid Indian address and will act as the official point of contact for tax authorities. The representative will also need to submit identity and address proof during the PAN application process.
Tax experts say this change increases accountability but may also add compliance responsibilities. Authorised representatives could receive official notices or queries from tax authorities if the foreign entity fails to comply with Indian tax requirements. In most cases, companies are expected to appoint senior executives or professional service firms for this role.
Tax Residency Rules Decide PAN Eligibility
- Residential status based on days spent in India
- Different PAN obligations for NRIs, RNORs, and foreigners
The rules also extend to non-resident Indians (NRIs) and resident but not ordinarily resident (RNOR) individuals. NRIs will now be required to provide their passport number when applying for a PAN. Authorities have clarified that tax residency status-not nationality-will determine PAN requirements.
The government has said these changes are aimed at improving transparency, strengthening compliance, and ensuring better tracking of foreign income and investments linked to India. While eligibility for PAN remains unchanged, the documentation and reporting requirements are now more detailed and structured.
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