• Service: Tax, International Tax
  • Type: Regulatory update
  • Date: 11/15/2013

India - “Fees for technical services” under treaty with Germany 

November 15:  The KPMG member firm in India prepared a report on the following development (read the November 2013 report by clicking on the hyperlink provided below):
  • Leather testing charges are taxable as “fees for technical services” under tax treaty with Germany - The Agra Bench of the Income-tax Appellate Tribunal held that leather testing charges were taxable as “fees for technical services” under the India-Germany income tax treaty because the treaty provides that the source state has a right to tax up to a specified rate, though the treaty uses the expression “may be taxed.” Further, the tribunal held that when the payment was made prior to the date of a retroactive change to the tax law, the payment was not taxable in India.

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