https://www.taxtmi.com/article/detailed?id=6221 Payments from an Indian division to its foreign head office that reimburse technical and administrative expenses were not treated as fees for technical services where no specific services were "made available", allowing deduction by the Indian PE without TDS under section 40(a)(ia) and placing the head office receipts outside Indian taxation under the relevant DTAA; this contrast with domestic treatment of branch and head office as one entity creates potential non taxation gaps, partially addressed by limited legislative changes but not comprehensively resolved. en-us Sat, 18 Apr 2015 06:27:16 +0530 Sat, 18 Apr 2015 06:27:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/article/detailed?id=6221 Payments from an Indian division to its foreign head office that reimburse technical and administrative expenses were not treated as fees for technical services where no specific services were "made available", allowing deduction by the Indian PE without TDS under section 40(a)(ia) and placing the head office receipts outside Indian taxation under the relevant DTAA; this contrast with domestic treatment of branch and head office as one entity creates potential non taxation gaps, partially addressed by limited legislative changes but not comprehensively resolved. Articles Income Tax Sat, 18 Apr 2015 06:27:16 +0530 https://www.taxtmi.com/article/detailed?id=6221