WebJan 29, 2024 · 20) [TS-5001-AAR-2010-O] – AAR holds that sums received by consultant under service agreement for supply of architectural designs & drawings are in nature of ’FTS‘ u/s 9(1)(vii) of the Act and u/Art 12.4 of the India-Germany DTAA, and cannot be regarded as consideration for sale of designs & drawings. 21) [TS-5014-AAR-2010-O] – … WebDouble Taxation Avoidance Agreement (DTAA). 3. Briefly the facts are, the assessee is a non-resident corporate ... (Appeals), it has to be seen whether it qualifies as FTS under India-UK DTAA, under which, the meaning of FTS is more restrictive than what is provided under India-Belgium tax treaty. As discussed earlier, Article
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WebJan 31, 2016 · The applicant requested for ruling on the followings issue – whether such management service fees is in the nature of “Fees for Technical Services” or “royalties” … WebApr 12, 2024 · • The option is useful if the persons say are very old and have no intention of going back and becoming again a non-resident ; • Since only 3 countries are notified till now , what is relevant to see is whether under DTAA these balances are taxable even when the assessee becomes a resident in India with the amounts locked up (tightly ) in funds … truttlecities
International Taxation >Double Taxation Avoidance …
Webthe Tribunal ruled that since the Indo-UK DTAA uses the expression „profits directly or indirectly attributable‟, the term „indirectly‟ invites application of the Force of Attraction ... This provision is also applicable to the India-Finland DTAA, which came in question in Roxon22. In the SNC Lavalin decision23, in relation to the WebJul 27, 2014 · Finding out information on this UK's tax contractual, related taxation documents and multilateral agreements. Tax treaties - GOV.UK / List of countries with whom India has Double Taxation Avoidance Agreement (DTAA) WebMay 22, 2024 · An Indian Tribunal affirmed that in the absence of being able to justify the supply of project specific technical designs/drawings/plans, capable of being used by an Indian entity for any subsequent projects, such supply can neither be construed as fees for technical services (FTS) under Article 13 (4) (c) of the India–U.K. tax treaty (tax … truttmann hearth ware