https://www.taxtmi.com/caselaws?id=32254 Amounts reimbursed under a genuine secondment arrangement, where the secondee remained on the foreign employer's payroll and the applicant paid only part of salary and related benefits, were treated as employment cost reimbursement rather than consideration for managerial, technical or consultancy services. On that basis, the reimbursements did not constitute fees for technical services or taxable income in the hands of the foreign employer under the Income-tax Act or the treaty, and no tax withholding obligation arose on the applicant. en-us Thu, 29 Jan 2009 00:00:00 +0530 Fri, 06 Mar 2009 13:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=32254 Amounts reimbursed under a genuine secondment arrangement, where the secondee remained on the foreign employer's payroll and the applicant paid only part of salary and related benefits, were treated as employment cost reimbursement rather than consideration for managerial, technical or consultancy services. On that basis, the reimbursements did not constitute fees for technical services or taxable income in the hands of the foreign employer under the Income-tax Act or the treaty, and no tax withholding obligation arose on the applicant. Case-Laws Income Tax Thu, 29 Jan 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=32254