https://www.taxtmi.com/forum/issue?id=119942 TDS applicability hinges on whether the payment is a pure reimbursement: if original invoices are in the Indian entity's name, no markup is charged, usage is attributable to the Indian subsidiary, and a clear inter-company agreement exists, TDS may not apply. However, where the AWS invoice is in the foreign holding company's name, usage is shared across jurisdictions, or documentation is insufficient, the reimbursement is likely to be treated as payment for services (potentially royalty or fees for technical services) attracting withholding under Section 195; therefore, withholding TDS and maintaining thorough supporting records or obtaining a CA certificate or a lower/NIL order is recommended. en-us Mon, 28 Apr 2025 19:14:40 +0530 Tue, 29 Apr 2025 12:47:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/forum/issue?id=119942 TDS applicability hinges on whether the payment is a pure reimbursement: if original invoices are in the Indian entity's name, no markup is charged, usage is attributable to the Indian subsidiary, and a clear inter-company agreement exists, TDS may not apply. However, where the AWS invoice is in the foreign holding company's name, usage is shared across jurisdictions, or documentation is insufficient, the reimbursement is likely to be treated as payment for services (potentially royalty or fees for technical services) attracting withholding under Section 195; therefore, withholding TDS and maintaining thorough supporting records or obtaining a CA certificate or a lower/NIL order is recommended. Discussion-Forum Income Tax Mon, 28 Apr 2025 19:14:40 +0530 https://www.taxtmi.com/forum/issue?id=119942