International Taxation -DTAA
This query is : Resolved
23 December 2010
Samples of product was sent by courier for testing and analysis by Indian company to a Non-resident company situated at Switzerland. A Non-resident company analyse the sample and gave us the test report, the analysis is upgradability test of the product and other technical work. The Indian Company received the test report, now Indian company wants to make payment for the technical work done by the Swiz company. The following queries are:
1. Now such payment by Indian company will become taxable income of the Swiz Company in India?
2.Such payment will fall under business profits or Fees for tecnical services?
3.which article of DTAA will apply for the above situation? Kindly advice as early as possible.
1. Now such payment by Indian company will become taxable income of the Swiz Company in India?
2.Such payment will fall under business profits or Fees for tecnical services?
3.which article of DTAA will apply for the above situation? Kindly advice as early as possible.
24 December 2010
1. Yes
2.Fees for Technical Services.
3.Article 12 but if the foreign company doesn't have PAN then 20% will be deducted.
2.Fees for Technical Services.
3.Article 12 but if the foreign company doesn't have PAN then 20% will be deducted.
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