https://www.taxtmi.com/caselaws?id=265679 Under the India-China DTAA, specialised product identification, market research, vendor interaction, quality monitoring, inspection, testing and information-sharing services were treated as managerial, technical or consultancy services, so the service fee paid by an Indian company to a non-resident for work performed in China was taxable in India as fees for technical services. The Authority held that Article 12 also deemed such fees to arise in India when paid by a resident, and that taxation applied to the gross receipt, not merely to the mark-up over cost. The receipt was therefore characterised as consultancy-based fees for technical services taxable at the treaty rate of ten per cent of the gross amount. en-us Mon, 28 Sep 2015 00:00:00 +0530 Wed, 04 May 2016 12:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=265679 Under the India-China DTAA, specialised product identification, market research, vendor interaction, quality monitoring, inspection, testing and information-sharing services were treated as managerial, technical or consultancy services, so the service fee paid by an Indian company to a non-resident for work performed in China was taxable in India as fees for technical services. The Authority held that Article 12 also deemed such fees to arise in India when paid by a resident, and that taxation applied to the gross receipt, not merely to the mark-up over cost. The receipt was therefore characterised as consultancy-based fees for technical services taxable at the treaty rate of ten per cent of the gross amount. Case-Laws Income Tax Mon, 28 Sep 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=265679