DTAA Implications
This query is : Resolved
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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?
CA R SEETHARAMAN
(Expert)
20 May 2020
Where is the location of third party and where service is provided.
CA R SEETHARAMAN
(Expert)
21 May 2020
Article. 15. Independent personal services.
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