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Provision of BPO services does not create service PE and hence not taxable as per DTAA.

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  • Provision of BPO services does not create service PE and hence not taxable as per DTAA.
Posted onon January 22, 2020January 22, 2020

Tenet Tax Daily January 14 2020

By tenettax-team
International Tax

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Company not entitled to DTAA benefit since place of effective management located in a third country
Consideration towards supply of embedded software treated as consideration for supply of goods and not royalty

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