Treatment of technical expenses when being reimbursed to head office of a non-resident enterprise by its branch office in India

Treatment of technical expenses when being reimbursed to head office of a non-resident enterprise by its branch office in India https://www.taxtmi.com/circulars?id=5065 Technical fees not characterised as head office executive and general administrative expenditure are deductible in full against the Indian permanent establishment's business profits, while the head office's receipt is taxable according to applicable tax treaty terms or, absent a treaty, relevant domestic provisions for nonresident receipts; assessing officers must verify genuineness and ensure tax collection safeguards, and the permanent establishment must comply with withholding obligations. en-us Wed, 31 Mar 1993 00:00:00 +0530 Sat, 09 Aug 2008 10:56:00 +0530 TaxTMI RSS Generator Treatment of technical expenses when being reimbursed to head office of a non-resident enterprise by its branch office in India https://www.taxtmi.com/circulars?id=5065 Technical fees not characterised as head office executive and general administrative expenditure are deductible in full against the Indian permanent establishment's business profits, while the head office's receipt is taxable according to applicable tax treaty terms or, absent a treaty, relevant domestic provisions for nonresident receipts; assessing officers must verify genuineness and ensure tax collection safeguards, and the permanent establishment must comply with withholding obligations. Circulars Income Tax Wed, 31 Mar 1993 00:00:00 +0530 https://www.taxtmi.com/circulars?id=5065