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Income Tax - Highlights / Catch Notes

Home Highlights May 2016 Year 2016 This

TDS u/s 195 - remittance towards ‘group cost recharge’ to its ...


India-Singapore DTAA: No Withholding Tax on 'Group Cost Recharge' as No Technical Services Under Article 12.

May 5, 2016

Case Laws     Income Tax     AT

TDS u/s 195 - remittance towards ‘group cost recharge’ to its associated enterprise(AE) in Singapore - impugned services rendered for which the payment was collected by Singapore entity through cost recharge mechanism is not assessable as ‘fee for technical services’ under Article 12 of India – Singapore DTAA when it does not ‘make available’ any technical knowledge, skill, experience, etc. - no legal obligation to deduct withholding tax on the impugned remittance - AT

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