ASTRONIFY CREATOR TAX & PAYOUT POLICY

1. PREAMBLE AND PURPOSE

This Astronify Creator Tax & Payout Policy ("Policy") is issued by Astronify Space Private Limited (hereinafter referred to as "Astronify," "we," "us," or "our") and sets forth the comprehensive terms and conditions governing all financial payments and tax-related obligations between Astronify and its content creators ("Instructors" or "you"). This Policy specifically addresses the procedures for payments made to Instructors who are not tax residents of India ("Non-Residents"). This Policy meticulously outlines the legal framework for tax withholding, mandatory documentation requirements, payout schedules, and compliance with all applicable Indian laws, including but not limited to the Income Tax Act, 1961. This Policy is an integral and non-severable part of the Astronify Instructor Terms and any related agreements entered into between you and Astronify.

2. DEFINITIONS

For the purpose of this Policy, the following terms shall have the meanings ascribed to them below:

• "Instructor" means any individual or legal entity who registers on the Astronify Platform, creates, uploads, and offers educational course content for sale, and is entitled to receive payments from Astronify.
• "Non-Resident" means an Instructor who is not a tax resident of India as per the criteria defined under Section 6 of the Income Tax Act, 1961 of India.
• "TRC" means a Tax Residency Certificate, a document issued by the competent tax authority of the Instructor's country of residence, confirming the Instructor's tax residency status.
• "Form 10F" means the self-declaration form prescribed under the Indian Income Tax Rules, which must be furnished by a Non-Resident to claim benefits under a Double Taxation Avoidance Agreement (DTAA) with India, in cases where the TRC does not contain certain prescribed particulars.
• "Domestic Rate" means the rate of tax withholding applicable under the provisions of the Indian Income Tax Act, 1961, in the absence of valid and complete documentation (TRC and Form 10F) required to claim a reduced rate under a DTAA.
• "DTAA" means a Double Taxation Avoidance Agreement, a bilateral tax treaty entered into between the Government of India and the government of another country.
• "TDS" means Tax Deducted at Source, which refers to the tax required to be withheld by a payer at the time of making a payment to a payee, as mandated by Indian law.
• "Form 27Q" means the quarterly TDS return that Astronify is legally obligated to file with the Indian tax authorities for all payments made to Non-Residents.
• "Form 16A" means the certificate for tax deduction at source issued by Astronify to the Instructor, certifying the amount of TDS deducted and deposited with the Indian Government.

3. LEGAL OBLIGATION AND BASIS FOR TAX WITHHOLDING

3.1. Statutory Requirement: You acknowledge and agree that under Section 195 of the Income Tax Act, 1961, Astronify is under a mandatory legal obligation to deduct TDS from any sum paid to a Non-Resident, where such sum is chargeable to tax under Indian law. The TDS must be deducted at the time of payment or at the time of credit of the income to the Instructor's account, whichever event occurs earlier.

3.2. Determination of Withholding Rate: The rate of TDS to be applied is determined in accordance with the provisions of the Income Tax Act, 1961, or the rates prescribed under an applicable DTAA, whichever is more beneficial to the Instructor. The benefit of a reduced rate under a DTAA can only be extended upon the Instructor's submission of the required, valid, and complete documentation.

3.3. Compliance Filings: Astronify is further obligated to comply with all associated statutory requirements, including the timely remittance of the deducted TDS to the Indian Government and the filing of Form 27Q (quarterly TDS return for non-resident payments) and issuance of Form 16A (TDS Certificate) to the Instructor.

4. DOCUMENTATION REQUIREMENTS

4.1. Mandatory Submission for DTAA Benefits: To avail the benefit of a reduced TDS rate under a DTAA, a non-resident Instructor must provide Astronify with the following documents:

• (a) A valid and up-to-date Tax Residency Certificate (TRC) covering the period for which the payment is being made; and
• (b) A duly completed and signed Form 10F, if the TRC does not contain the following particulars:
• (i) Status (individual, company, firm, etc.) of the Instructor;
• (ii) Nationality (for individuals) or country of incorporation/registration (for legal entities);
• (iii) Tax identification number of the Instructor in their country of residence;
• (iv) Period for which the TRC is applicable; and
• (v) Address of the Instructor in their country of residence.

4.2. Digital Submission: Astronify shall provide a secure, digital mechanism within its Instructor Dashboard (Creator Portal) for the submission of the TRC and Form 10F. Instructors are required to upload these documents prior to their first payout and to renew them at the beginning of each new Indian financial year (April 1st to March 31st) or whenever the validity period of the TRC expires.

4.3. Default Withholding: In the event that an Instructor fails to provide a valid and complete TRC and/or Form 10F, or if the documents provided are deemed incomplete, invalid, or expired by Astronify, Astronify shall be entitled to deduct TDS at the Domestic Rate as prescribed under the Income Tax Act, 1961, without any further notice. This default withholding shall continue until such time as the Instructor provides the required valid documentation.

5. WITHHOLDING TAX RATES

5.1. DTAA Rate: If an Instructor provides all the valid documentation as per Section 4, Astronify shall apply the reduced TDS rate stipulated in the applicable DTAA between India and the Instructor's country of residence. The rate shall be based on the characterization of the income as "royalty" or "fees for technical services" under the DTAA.

5.2. Domestic Rate: In the absence of the documentation required under Section 4, Astronify shall deduct TDS at the higher of the rate prescribed under the Income Tax Act, 1961, or the applicable DTAA rate. As of the Effective Date of this Policy, the statutory TDS rate for payments characterized as royalty or fees for technical services to Non-Residents is 10% (ten percent), plus any applicable surcharge and health and education cess, as per the relevant Finance Act.

6. PAYOUTS

6.1. Payment Mechanism: Payouts to Instructors shall be made in U.S. Dollars (USD) via the third-party payment processors specified by Astronify, which may include Stripe Connect or PayPal, as per the terms of the Instructor Agreement.

6.2. Payout Schedule: Astronify shall release the net payout (after deduction of all applicable TDS and other deductions) within forty-five (45) days after the end of each calendar month. All payouts are subject to a minimum payout threshold as specified in the Instructor Terms.

6.3. Adjustments and Deductions: Astronify reserves the right to adjust, reduce, or offset the Instructor's payable amount to account for any refunds issued to learners, chargebacks, or any other losses or fees incurred by Astronify in connection with the Instructor's course.

7. FILING AND CERTIFICATES

7.1. TDS Deposit: Astronify is responsible for depositing the TDS amount deducted with the Indian Government by the due date prescribed under the Income Tax Act, 1961 (generally the 7th day of the following month).

7.2. Form 27Q Filing: Astronify shall file Form 27Q with the Indian tax authorities for each calendar quarter, providing a consolidated report of all payments made to Non-Residents and the corresponding TDS deducted.

7.3. Form 16A Issuance: Upon filing of the Form 27Q for a particular quarter, Astronify shall issue a Form 16A (TDS Certificate) to the Instructor. This certificate will detail the gross payments made, the TDS deducted, the period for which the deduction was made, and the PAN of both the deductee (Instructor) and the deductor (Astronify). Form 16A will be made available to the Instructor through the Creator Portal within fifteen (15) days after the due date for filing the relevant Form 27Q return.

8. REMITTANCES AND RECORD-KEEPING

8.1. Remittance Compliance: Astronify shall adhere to all compliance requirements of the Reserve Bank of India for all cross-border remittances of net payouts to Non-Residents. This includes, if and as required by Indian law, the submission of self-declarations in Form 15CA and a Chartered Accountant's certificate in Form 15CB.

8.2. Record Retention: Astronify shall maintain electronic or physical records of all TRCs, Form 10Fs, invoices, payout calculations, TDS deposit challans, and TDS certificates for a minimum period of seven (7) years or for such longer period as may be required under applicable law.

9. REPORTING AND DISPUTE RESOLUTION

9.1. Information Access: Instructors may, through the Creator Portal, access and request copies of their payout calculations (showing gross earnings, deductions, and net payable) and their TDS Certificates (Form 16A).

9.2. Dispute Process: If an Instructor believes that an incorrect amount of TDS has been deducted due to a wrong rate or a processing error, they may submit a formal written objection to Astronify within thirty (30) days from the date of issuance of the relevant Form 16A. Astronify shall, in good faith, investigate the objection and, if an error is confirmed, shall take reasonable steps to correct the error in a subsequent payout.

10. INDEMNIFICATION

You, the Instructor, hereby agree to indemnify, defend, and hold harmless Astronify, its directors, officers, employees, affiliates, and agents from and against any and all claims, liabilities, losses, damages, costs, or expenses (including reasonable legal fees) arising from or in connection with:

• (a) Your failure to provide valid, accurate, and complete documentation required for tax withholding;
• (b) Any misrepresentation of your tax residency, beneficial ownership, or other information provided by you;
• (c) Your failure to comply with your own personal tax obligations in your country of residence; or
• (d) Any claims, demands, or penalties imposed by a tax authority that result from inaccurate information you have provided to Astronify.

11. AMENDMENTS

Astronify reserves the right to amend, modify, or update this Policy from time to time to ensure compliance with changes in Indian law or for other business reasons. We shall provide you with a prior written notice of any material changes, not less than thirty (30) days in advance. Your continued receipt of payouts or use of the Services after the effective date of such amendments shall constitute your binding acceptance of the revised Policy.

12. GOVERNING LAW AND JURISDICTION

This Policy shall be governed by and construed in accordance with the laws of India. Any dispute, controversy, or claim arising out of or relating to this Policy, including its formation, interpretation, breach, or termination, shall be subject to the exclusive jurisdiction of the competent courts located in Bangalore or Delhi, India.