What is the liability for deduction of tax at source u/s 195 on payments made to non residents not having any business entity in India towards foreign marketing consultancy / marketing liasion fee paid prior to union budget 2010 and post union budget 2010.
e.g. A Indian company engaged in IT enable services has engaged marketing consultants in UK and USA. for exploring market potentials, liasion with clients abroad.
normally when payment made to non residents the sections applicable are section 5,9 and section 195. as per section 195, the income of NR should be chargeable to tax. It is better to deduct tax if the payer is not familiar with DTAA provisions of that country. Now in budget, the NR is chargeable to tax in India even if he is performing duties outside India as per section 9.
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