Corporate guarantee - fee for technical services (FTS) under ...

Case Laws Income Tax

March 25, 2020

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 not being in the nature of services of managerial, technical or consultancy, the corporate guarantee fee received by the assessee cannot be termed as fee for technical services either under the section 9(1)(vii) or under article of the DTAA.

View Source

← Previous Next →

Corporate guarantee - fee for technical services (FTS) under ...

Case Laws Income Tax

March 25, 2020

You may also like:

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...

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...

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...

Taxability of Fees for technical services (FTS) - In Article–13(4)(c) of the India–UK tax treaty the words “or consists of the development and transfer of a technical...

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...

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...

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 assessee's income received from Indian customers as Fee for Technical Services (FTS)/Fee for Included Services (FIS) u/s 9(1)(vii) of the Act and Article 12(4) of...

TDS u/s 195 - Taxability of income in India - PE in India - taxation of offshore supplies - Taxation of Fee for Technical Services (FTS) in the absence of FTS article...

Income accrued or deemend to accrue in India - Fees for technical services' under Article 12(5)(a) of the India-Netherlands tax treaty - as providing of access to CRS,...

Income accrued In India - 'Royalty' or 'Fees for Technical Services' under Section 9(l)(vi) and 9(l)(vii) - the payment made by SCB to assessee- company does not fall...

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...

The case involved the taxability of Fees for Technical Services (FTS) u/s India-Thailand DTAA. The Appellate Tribunal held that if revenue arises from "profits of an...

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

Taxability of foreign income in India - business connection’ in India or not? - subscription services - ITAT came to the factual finding that the arrangement between...

Quick Updates: