Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding
  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights June 2018 Year 2018 This

Withholding of tax u/s 195 - fee for technical services (FTS) - ...


MFN Clause Applies to India-Sweden DTAA for Withholding Tax on Technical Service Fees Without Notification Requirement.

June 26, 2018

Case Laws     Income Tax     AT

Withholding of tax u/s 195 - fee for technical services (FTS) - the protocol itself makes it clear that the said ‘MFN’ clause “shall apply” in India-Sweden DTAA. - Issuance of a notification has nowhere been stipulated as a condition precedent therein.

View Source

 


 

You may also like:

  1. Accrual of income in India - Fees for technical services (FTS) - taxability of receipts towards Human Resource and Leadership training provided by the assessee to its...

  2. TDS u/s 195 not deducted on payment to Everest Global Inc. for software training services as source of income located outside India and payment made for services outside...

  3. 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)...

  4. 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...

  5. 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...

  6. The key points in the legal document are: Software licensing amounts do not qualify as Fees for Included Services under Article 12(4)(b) of the India-US DTAA, as the...

  7. Taxability of income in India - receipts from services rendered to Indian entities - Fee for Technical Services (FTS) - Despite the assessee's contention that the...

  8. The income deemed to accrue or arise in India, including reimbursement received for SAP Software and Microsoft License fees, was held to be taxable as royalty receipts...

  9. TDS u/s 195 - Disallowance of management fee paid by invoking the provisions of section 40(a)(i) - whether payment of management fees cannot be regarded as fees for...

  10. Income taxable in India - payments received from its India customers on account of Centralized Services - Fee for Technical Services - Fee for included services - The...

  11. Income accrued in India - Fee for Technical Services [FTS] - 'make available’ - the marketing and sales services, operations and standardization services do not satisfy...

  12. 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...

  13. TDS u/s 195 - professional services - Fees for Technical Services (FTS) - the definition of “Fees for Technical Services” has to be given a restrictive meaning similar...

  14. Income chargeable to tax as FIS in India - Fee for included service - The e-publishing work in the nature of editorial services comprising of page composition, language...

  15. The assessee earned income from professional services rendered in foreign countries like Japan, Nepal, and Singapore. The Income Tax Appellate Tribunal (ITAT) examined...

 

Quick Updates:Latest Updates