25 June 2012
Does a remittance to a holding company situated outside India by a subsidiary company attract TDS u/s 195? The remittance is for the services provided by the holding company outside India.
03 July 2012
Firstly, unlike a branch, Subsidiary is an independent entity. Secondly, provision of services may be taxable irrespective of fact that its not rendered in India (Ref expl to Sec 9). Also DTAA may tax the same at reduced rates.