TMI BlogPerfetti India's Payments Taxed Under Article 12.5(a) & (b) of Double Taxation Agreement: AAR Insights on FTS Fees.Double taxation Agreements - Meaning of fees for technical services (FTS) - allocated of cost - the applicant is taxable under Article 12.5(a) and as also under Article 12.5(b) - the payment made by Perfetti India would be chargeable to tax in India..... - AAR ..... X X X X Extracts X X X X X X X X Extracts X X X X
|