https://www.taxtmi.com/forum/issue?id=3305 Payment characterisation controls withholding: where the parent's charge for server use is consideration for services (fee for technical services or royalty) withholding under section 195 applies; where the parent is merely reimbursing an external supplier and provides matching third party invoices as support, the payment is treated as reimbursement and withholding would not apply. en-us Tue, 23 Aug 2011 10:47:33 +0530 Thu, 23 Jan 2025 15:58:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/forum/issue?id=3305 Payment characterisation controls withholding: where the parent's charge for server use is consideration for services (fee for technical services or royalty) withholding under section 195 applies; where the parent is merely reimbursing an external supplier and provides matching third party invoices as support, the payment is treated as reimbursement and withholding would not apply. Discussion-Forum Income Tax Tue, 23 Aug 2011 10:47:33 +0530 https://www.taxtmi.com/forum/issue?id=3305