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 October 2020 Year 2020 This

Levy of tax on the royalties or fees for technical services - ...

Case Laws     Income Tax

October 8, 2020

Levy of tax on the royalties or fees for technical services - rate of tax under the DTAA - 12% or 10% - the substitution has the effect of deleting the old rule and making the new rule operative. Therefore, the Tribunal has rightly determined the rate of tax as substituted in Clause 2 of Article 12 of DTAA between India and Singapore applicable for the entire fiscal year as defined in DTAA and is liable to be taxed at 10%. - HC

View Source

 


 

You may also like:

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

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

  3. Levy of Surcharge and cess - to be computed over the rate of tax as per DTAA or not - Article 12 read with Article 2 of the tax treaty makes it clear that the rate of...

  4. Rate of service tax increased from 10% to 12%

  5. 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)...

  6. Levy of service tax - supplementary invoice - cost escalation clause - to be taxed at 12% or at 10% - the taxable events in the present Appeal had admittedly occurred...

  7. 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...

  8. 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...

  9. TDS Liablity - fees for technical services - payment of rArchitectural services and Interior designing and Architectural services - Since, we have held that the payments...

  10. TDS u/s 195 - site testing charges - Royalty - the services which can independently or on stand alone basis, be provided, coupled with the fulfillment of the other...

  11. Income accrued in India - Taxability of foreign income in India - Royalty receipt - Only difference is that it relates to royalty under India- Switzerland DTAA, and...

  12. 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...

  13. 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...

  14. 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...

  15. Clubbing of income of Non-resident and Permanent Establishment (PE) - Levy of surcharge at 5% as against assessee’s claim of 2% - The royalty and Fee for Technical...

 

Quick Updates:Latest Updates