21 December 2010
A vendor having no PE in India provides over the phone language interpretation services to a BPO based in India. None of its interpreters are based in India. Services are given on the telephone. Whether such services tantamount to make available expertise/technical knowledge so as to being liable to WHT under Article 12 of Indo-US DTAA?
22 December 2010
If the country of remittance is USA then the same may not tantamount to make available and hence may not be taxable in India.Kindly make sure that the LOB clause in India USA Treaty is taken care of while taking relief under any clause of India USA Treaty.
CAclubindia
