Tds u/s 195 for payment made outside india in uk

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What is applicability of TDs & service tax if service receiver is an Indian LLP receiving advertisement  services outside India from service provider outside India who does not have an permeant establishment in India...

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TDS u/s. 195 would be applicable, but no service tax liability (under RCM) when services provided out of India.

Since the Entire Service is received outside India the Income accrues outside India.

TDS under Section 195 will be applicable but the Benefit of Article 7 of DTAA with UK can be availed which requires deduction of TDS only if there is a Permanent Establishment in India.

Service Tax would be applicable as Place of Provision Rules which states that when the recepient of Service is in India Service tax has to be paid under reverse charges by the Service Recepient.

Thanks for the reply


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