Company "A" is incorporated in US as a private LLC having 100% owned subsidiary in India. The Indian subsidiary is providing IT enabled services India. From 2021 they want to recharge some software licensing costs like MS office , SAP costs etc to India
Company proposes to recharge $100K- 200K
Questions
1)Tax on such recharge
2) Any specific guideline to be followed
3) what are the conditions needed to be met for ADF US and ADF India to eligible for interpretation.
Company "A" is incorporated in US as a private LLC having 100% owned subsidiary in India. The Indian subsidiary is providing IT enabled services India. From 2021 they want to recharge some software licensing costs like MS office , SAP costs etc to India
Company proposes to recharge $100K- 200K
Questions
1)Tax on such recharge
2) Any specific guideline to be followed
3) what are the conditions needed to be met for US corporation and Indian corporation to eligible for interpretation.