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Revenue allocated to German HO by Indian BO not taxable in India as India-Germany DTAA allows “fee splitting arrangement”

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  • Revenue allocated to German HO by Indian BO not taxable in India as India-Germany DTAA allows “fee splitting arrangement”
Posted onon July 25, 2013July 25, 2013

Tenet Tax Daily July 25 2013

By tenettax-team
International Tax

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Mere submitting an incorrect claim without malafide intention doesn’t attract concealment penalty
Payment received by foreign company from Indian franchisee for international marketing activities is not “royalty” under Article 12(4) of DTAA even if its on the basis of % of gross revenue

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