What is the DTAA rate of tax at which tds is to be deducted u/s 195 for amount payable by an Indian co. to its parent Company in USA in respect of professional services renedered by the Non resident Foreign Co. to the Indian Co.
What is the DTAA rate of tax at which tds is to be deducted u/s 195 for amount payable by an Indian co. to its parent Company in USA in respect of professional services renedered by the Non resident Foreign Co. to the Indian Co.
For purposes of this Article, fees for included services means payments of any kind to any person in consideration for the rendering of any technical or consultancy services (including through the provision of services of technical or other personnel) if such services :
(a) are ancillary and subsidiary to the application or enjoyment of the right, property or information for which a payment described in paragraph 3 is received ; or
(b) make available technical knowledge, experience, skill, know-how, or processes, or consist of the development and transfer of a technical plan or technical design.
(FOR DETAIL REFER ARTICLE 12 OF INDO USA DTAA)
Regards,
Chirag Haraniya
Karia Overseas
Ahmedabad
CA
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