https://www.taxtmi.com/forum/issue?id=3624 Whether withholding tax must be deducted on payments to a foreign company for short-term services performed in India hinges on payment characterization and whether the income is attributable to a permanent establishment. If the workshop services are attributable to a PE in India, India may tax the income and require withholding; if not attributable and the DTAA excludes taxation in India or provides relief, reduced withholding or exemption may apply. Factual determination of place of performance, nature of presence or agent, and relevant DTAA articles is required. en-us Tue, 06 Dec 2011 15:44:13 +0530 Thu, 23 Jan 2025 15:58:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/forum/issue?id=3624 Whether withholding tax must be deducted on payments to a foreign company for short-term services performed in India hinges on payment characterization and whether the income is attributable to a permanent establishment. If the workshop services are attributable to a PE in India, India may tax the income and require withholding; if not attributable and the DTAA excludes taxation in India or provides relief, reduced withholding or exemption may apply. Factual determination of place of performance, nature of presence or agent, and relevant DTAA articles is required. Discussion-Forum Income Tax Tue, 06 Dec 2011 15:44:13 +0530 https://www.taxtmi.com/forum/issue?id=3624