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MFN Clause Applies to India-Sweden DTAA for Withholding Tax on Technical Service Fees Without Notification Requirement.
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....Withholding of tax u/s 195 - fee for technical services (FTS) - the protocol itself makes it clear that the said ‘MFN’ clause “shall apply” in India-Sweden DTAA. - Issuance of a notification has nowhere been stipulated as a condition precedent therein.....
TaxTMI
TaxTMI