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Learn moreBifurcated portion of service fee is taxable in India as business income
The Delhi High Court held that that to the extent a service fee arising from a single contract is attributable to a nonresident’s permanent establishment (PE) in India, the bifurcated portion of such fee is taxable in India as business income.
The remaining part of the service fee could be taxed as a fee for technical services (FTS), but in the case before the court, the services did not satisfy the “make available” test of the FTS article under the India-UK tax treaty and thus were not subject to tax in India as FTS.
The case is: International Management Group (UK) Limited v. CIT
Read a July 2024 report prepared by the KPMG member firm in India
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