Dtaa-meaning of fixed base

 

Our client has availed services of its directors in the nature of consultancy services.But they have not deducted any TDS from it.The AO is saying that since the directors are the only shareholders of the company, they are having 'fixed base' in the form of company in India,hence the income is taxable under Article 15 of DTAA btwn India and USA.

 

Please advice whether the contention of AO is correct.Also tell me if there is any difference btwn PE and fixed base.Tell me about any case laws where the concept of fixed base has ben discuused in detail. 

Replies (1)

Being a corporate house, you should avail the services of specially appointed legal expert on the subject.

Leave a Reply

Your are not logged in . Please login to post replies

Click here to Login / Register  

Company
05 October 2026
Senior Accountant

Vision IT Peripherals Pvt Ltd

Mumbai

B.Com

View Details
Company
ARTICLESHIP 20 October 2026
CA ARTICLE

AMKN & CO

Noida

CA Inter

View Details
Company
16 October 2026
CA article trainee

Zerdi & Co. Chartered Accountants

Pune

CA Inter

View Details
Company
ARTICLESHIP 30 September 2026
CA Article Assistant

CA Suraj Garg & Associates

New Delhi

CA Final

View Details
Company
Featured ARTICLESHIP 06 October 2026
Semi Qualified

AJAY SINGH AND CO LLP

Thane

CA Final

View Details
Company
14 October 2026
Accountant

Rize.farm

Bengaluru

B.Com

View Details
Company
30 September 2026
Senior Accounts Executive

Codeboard Technology

Chennai

MBA

View Details
Company
ARTICLESHIP 01 October 2026
Articled Assistant

KPSN & Associates LLP

Chennai

CA Inter

View Details