Fees for technical services (FTS) - India France DTAA - claiming ...

Income Tax

January 31, 2023

Fees for technical services (FTS) - India France DTAA - claiming the benefit of the restricted definition under India USA DTAA - Since the assessee has been found not to have ‘made available’ any technical knowledge, experience, skill, or know-how, therefore, Management Service Fees received by the assessee cannot be taxed under the provisions of Article 13 of the India France DTAA read with para 7 of the Protocol to the India France DTAA and Article 12(4) of India USA DTAA. - AT

View Source

← Previous Next →

Fees for technical services (FTS) - India France DTAA - claiming ...

Income Tax

January 31, 2023

You may also like:

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...

Clubbing of income of Non-resident and Permanent Establishment (PE) - Levy of surcharge at 5% as against assessee’s claim of 2% - The royalty and Fee for Technical...

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

Taxability in India - amount received by the assessee from offshore supplies of plants and equipments - PE in India or not? - The Tribunal questioned the differential...

Standby maintenance revenues earned under the Construction and Maintenance Agreement (C&MA) from VSNL - whether taxable in India as ‘Fees for Technical Services’ (‘FTS’)...

The notification, issued by the Ministry of Finance, pertains to the modification of the Convention between the Government of India and the Kingdom of Spain for the...

TDS u/s 195 - disallowance u/s 40(a)(i) - payment to a foreign entity as testing /certification fees outside India - the assessee bonafidely believed that such...

Section 90 of the Income-tax Act, 1961 - Double Taxation Agreement - Agreement for Avoidance of Double Taxation and Prevention of fiscal evasion with foreign countries -...

Taxability as Fee for Included Service (FIS) u/A 12 of India-USA DTAA - As per Example 7 of the Memorandum of Understanding to India-USA DTAA, a receipt cannot be...

Income deemed to accrue or arise in India - Fee for Technical Services (FTS)/ Fee for Included Services (FIS) - the services provided by the assessee under the marketing...

Quick Updates: