my client is an 100% subsidiary of a us company.the us company provide some technical services to its indian subsidiary in relation to consultancy project running in india with the government department.
my question is what rate of tds is applicable on payment to us company for technical services?
i come up with following these
A. Dtaa rate 15% flat
B. 115A(1)(b) 10% plus
C. 44DA 10% plus As per ready reckoner but general rate is 40% ----------
please clarify this. Is ready recknor correct.?
further if it is PE Transaction lower would be of DTAA and 44AD.
whether we need to obtain pan of us holding company and what are the implications for filing return?.
very thanks to all .
CAclubindia
