International taxation

This query is : Resolved

Querist : Anonymous

Querist : Anonymous (Querist)

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.

Arihanth Jain

Arihanth Jain (Expert)
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29 June 2012 Yes, may attract very much.

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Querist : Anonymous

Querist : Anonymous (Querist)

03 July 2012 Can u pls explain as to how it is taxable?

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Arihanth Jain

Arihanth Jain (Expert)
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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.

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Querist : Anonymous

Querist : Anonymous (Querist)

04 July 2012 thanks a lot!