https://www.taxtmi.com/forum/issue?id=5249 If payments to the foreign parent qualify as taxable technical service or similar income under domestic source rules and the India-Japan DTAA, the payer must withhold tax at source under domestic withholding law and the treaty; whether the withheld tax is creditable and the correct characterization of the payment requires detailed factual and legal examination, including consideration of the nature of services and any permanent establishment or fixed base. en-us Tue, 29 Jan 2013 09:44:40 +0530 Thu, 23 Jan 2025 15:57:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/forum/issue?id=5249 If payments to the foreign parent qualify as taxable technical service or similar income under domestic source rules and the India-Japan DTAA, the payer must withhold tax at source under domestic withholding law and the treaty; whether the withheld tax is creditable and the correct characterization of the payment requires detailed factual and legal examination, including consideration of the nature of services and any permanent establishment or fixed base. Discussion-Forum Income Tax Tue, 29 Jan 2013 09:44:40 +0530 https://www.taxtmi.com/forum/issue?id=5249