https://www.taxtmi.com/article/detailed?id=13872 Outward secondment arrangements implicate Service PE, Fees for Technical Services, transfer pricing and export of service GST treatment: a Service PE may arise where seconded employees remain deployed overseas and lien over employment remains with the Indian entity; FTS requires making available technical knowledge; resident Indian entities remain taxable on worldwide income subject to DTAA relief; reimbursements without markup are typically not taxable while markups received in India are taxable and require arm's length justification; GST export treatment depends on whether supplier and recipient are separate legal persons and whether IGST conditions are satisfied. en-us Fri, 21 Mar 2025 08:29:25 +0530 Fri, 21 Mar 2025 08:29:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/article/detailed?id=13872 Outward secondment arrangements implicate Service PE, Fees for Technical Services, transfer pricing and export of service GST treatment: a Service PE may arise where seconded employees remain deployed overseas and lien over employment remains with the Indian entity; FTS requires making available technical knowledge; resident Indian entities remain taxable on worldwide income subject to DTAA relief; reimbursements without markup are typically not taxable while markups received in India are taxable and require arm's length justification; GST export treatment depends on whether supplier and recipient are separate legal persons and whether IGST conditions are satisfied. Articles Goods and Services Tax - GST Fri, 21 Mar 2025 08:29:25 +0530 https://www.taxtmi.com/article/detailed?id=13872