Foreign exchange system services provided - Article 13 Indo-UK ...

Case Laws Income Tax

July 27, 2014

Foreign exchange system services provided - Article 13 Indo-UK DTAA – once the receipt has been decided as royalty in nature then there is no need to go into the question of assessee having PE in India - - AT

View Source

← Previous Next →

Foreign exchange system services provided - Article 13 Indo-UK ...

Case Laws Income Tax

July 27, 2014

You may also like:

Income taxable in India - cellular roaming charges - India-UK DTAA under Article 13(3) - Royalty - VIL already possessed the process used for providing roaming services...

Addition on account of services rendered by the assessee to its AE in India - whether FTS under the provisions of Article 13(4)(c) of the India-UK DTAA? - the...

Disallowance u/s 40(a)(ia) - failure to deduct TDS u/s 195 - in view of Protocol between India and Spain, the restrictive meaning of ‘Fee for Technical Services’...

Fees for Technical Services (FTS) - The AO himself has stated that some of the services are of the nature of FTS. Thus, AO clearly admits that all the services rendered...

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 or deemed to accrue in India - As the design services were inextricably connected with setting up of the plant and were rendered through this PE, the...

Taxability of receipts as 'fees for included services' under the India-USA Double Taxation Avoidance Agreement (DTAA). The key points are: The Assessing Officer (AO)...

Insurance Auxiliary Services - brokerage received from overseas reinsurance - Export of service or not - Non receipt of consideration in foreign exchange - the basis of...

This circular clarifies the position regarding advertising services provided by Indian advertising companies/agencies to foreign clients. It addresses three key issues:...

This circular clarifies the determination of place of supply and export benefits for advertising services provided by Indian advertising agencies to foreign clients. Key...

Establishment of PE in India – service PE - Article 5 of Indo-UK DTAA – It is thus rightly held that the service PE of the assessee is established in India - AT

The assessee received amounts from Indian customers for supplying software updates, patches, and on-call support services. The issue pertained to taxability of these...

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...

Foreign tax credit claimed under Article 24 of India- UK DTAA read with Section 90 - assessee who is a resident of India and has derived from salary which has suffered...

FTS in the given case would be taxed at the beneficial rate of 15% on gross receipts as provided in Article 13(2) of the India-UK DTAA. - the tax liability borne by GRSE...

Quick Updates: