This article delves into the tax and Goods and Services Tax (GST) implications for Indian businesses engaging in outward secondment arrangements, where employees are temporarily transferred overseas. It explores key considerations such as the establishment of a Service Permanent Establishment (PE) and the applicability of Fees for Technical Services (FTS), highlighting how Double Taxation Avoidance Agreements (DTAAs) influence these aspects. The piece also examines four distinct scenarios, offering guidance on structuring secondment agreements to optimise tax benefits and ensure compliance with Indian regulations.
As Indian businesses continue to expand their global footprint, outward secondment arrangements have become increasingly common. These arrangements involve the temporary transfer of employees from an Indian entity to an overseas entity, often raising complex questions around tax and GST implications
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