Mnc holding company require to file income tax return?

This query is : Resolved

Querist : Anonymous

Querist : Anonymous (Querist)

14 December 2015 Dear Sir,

A spain based Holding company holds 70% stake in Indian company. Which is acquired by purchasing the Portuguese company. The spain company is receiving payment for technical services and guarantee pay.
Further, it has no business connection other than the company acquired in India which is a subsidiary of portugisee company. Whether Spain based company is required to file Income tax return in India?

An indian company is filing Income tax return regularly. Please give the reference base for my learning experience.

Thanking you in advance.

Regards
A Learned Member. :)

Guest

Guest (Expert)

15 December 2015 According to most of DTAA, technical services will be taxed both in resident country and source country with DTAA relief. Even if there is no Permanent establishment in India, the same shall be taxed. Consequently, the return need to be filed for holding company.