DTAA Implications

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This discussion examines the Double Taxation Avoidance Agreement (DTAA) implications when an Indian party and an Italian party jointly provide M&A services to a client located and serviced in Italy. The arrangement involves the Indian party invoicing the client and receiving the full payment, then paying the Italian party a success fee. The core question is whether this remittance attracts DTAA provisions, specifically under Article 15 concerning independent personal services.

soniya

soniya (Querist)
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20 May 2020 An indian party and an Italy party had jointly provided M&A services to a third party. Now as per oral arrangement between both the service providers the invoice will be raised by indian party also whole consideration will be received by Indian party only and then Italy party will issue invoice as success fee to indian party and upon that their share will be remitted to other service provider in Italy whether this remittance attracts DTAA provision if yes which article which cover this type of transaction?