Wednesday, 4 February 2015

NR rendering support services to Indian affiliate via seconded employees constituted its service PE

IT/ILT : Where assessee, a foreign company seconded some of its employees to India to render their services to Indian subsidiary companies, those employees constituted assessee's service PE in India and salary cost of said employees reimbursed by Indian companies was taxable in India in terms of article 7 of Indian USA DTAA


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