Reimbursement of salary cost treated as fees for technical ...

Salary Reimbursements Classified as Fees and Royalties u/s 9(1)(vii) and Article 7 of Indo-US DTAA.

December 22, 2014

Case Laws Income Tax AT

Reimbursement of salary cost treated as fees for technical services – Royalty u/s 9(1)(vii) – Indo-US DTAA - If there is a PE, then Royalty or FIS cannot be taxed under Article 12, albeit only under Article 7 of the DTAA - AT

View Source

← Previous Next →

Reimbursement of salary cost treated as fees for technical ...

Salary Reimbursements Classified as Fees and Royalties u/s 9(1)(vii) and Article 7 of Indo-US DTAA.

December 22, 2014

Case Laws Income Tax AT

You may also like:

Income accrued in India - Royalty u/s.9(1)(vi) - intra-group services fees - Coming to the Indo-Spain DTAA, it is axiomatic that the domestic law has not been linked...

Corporate guarantee - fee for technical services (FTS) under article 13 of the India France DTAA and section 9(1)(vii) - services of corporate guarantee by the assessee...

Income accrued in India - tratement of Income from cloud hosting services as royalty - income from cloud hosting services has erroneously held as royalty within the...

The court examined whether the receipts from services rendered by IMG to BCCI for IPL were taxable as Fees for Technical Services (FTS) under Article 13 of the India-UK...

Income accrued In India - 'Royalty' or 'Fees for Technical Services' under Section 9(l)(vi) and 9(l)(vii) - the payment made by SCB to assessee- company does not fall...

Royalty/fees for technical services u/s. 9 (1) (vi)/9 (1)(vii) - payment made by SCB to assessee company does not fall within the realm of “fees for technical...

Income accrued in India -Treating subscription fee received from the clients in India as Royalty/FTS within the meaning of section 9(1)(vi) and 9(1)(vii) r.w. Article...

The Appellate Tribunal addressed the issue of characterizing interconnect utility charges (IUC) as 'Royalty' for TDS u/s 195 of the Income Tax Act and India-Japan DTAA....

Fee for Technical services - DTAA with Singapore - Section 9(1)(vii) of the Income tax - fee paid for training, in-class teaching and on-line teaching - not taxable - AAR

The ITAT ruled that the Indian entity (RIC) was not a dependent agent permanent establishment (DAPE) under Article 5 of the USA-India DTAA, following its previous...

TDS u/s 195 - Payments for software licenses fees as 'Royalty' as per Section 9(1)(vi) - Unilateral amendment by the Indian Government to the term ‘royalty’ by way of...

Income taxable in India - Taxability of the receipts as “Royalty" - telecom services comprising of interconnectivity services - Once the situs is outside India, then in...

Income deemed to accrue or arise in India - licensing of software products of Microsoft in the Territory of India by the Respondent was not taxable in India as Royalty...

TDS u/s 195 - non deduction of tds on software expenses representing reimbursement of software cost to its parent company - it cannot be held as ‘royalties’ coming into...

The ITAT considered the issue of Fee for Technical Services (FTS) u/s 9(i)(vii) in a case involving reimbursement of connectivity charges. Assessing whether the services...

Quick Updates: