Tds on foreign remittance

Dear All, I need an opinion on below issue. We are making payment to our sister concern in Thailand. This payment are in nature of 1. Payment for IT services and support provided by Thailand 2. Some common expenses incurred by Thailand on our behalf and reimbursed by us My query is whether a) TDS is attracted as per section 195? b) Also TDS is applicable on reimbursements? DTAA exists between India and Thailand still TDS applicable? If yes is it the same rate @ 10.3% with PAN and 25.75% without PAN? Looking forward for your valuable inputs. Thanks! Awaiting your valuable opinions.