Foreign llp
This query is : Resolved
18 November 2013
in the definition of person,sec2(31), foreign company is included but what about foreign llp? wont that be taxed on its Indian income? is it included in the definition of person? if yes, which provision or case law states so?
07 January 2014
given that the definition of company also includes body corporate incorporated in or outside India, LLP's can easily be included in the same category.
however, needless to say no position in taz law is as simple as LLPs have often been denied benefits of DTAA because of obscurity regarding their tax status (read clifford chance AAR)https://www.pwc.co.uk/en_UK/uk/assets/pdf/foreign-law-firms-providing-services-in-india-june2013.pdf
however, needless to say no position in taz law is as simple as LLPs have often been denied benefits of DTAA because of obscurity regarding their tax status (read clifford chance AAR)https://www.pwc.co.uk/en_UK/uk/assets/pdf/foreign-law-firms-providing-services-in-india-june2013.pdf
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