south african company

S. 9, Treaty with South Africa; in favor of taxpayer: - Z, a South African company, offered to promote and market the products of the taxpayer, an Indian company, on commission basis. Z will procure and negotiate orders and forward these to the taxpayer. The taxpayer will execute the orders directly and will receive the consideration in India. Z will render all services outside India and will not maintain any PE in India. Full Article

The Authority for Advanced Ruling has ruled that if an Indian company pays a commission to an overseas company to promote its business in that country, such payment will not be taxable in India. The AAR, a quasi judicial body on matters of taxation, in a ruling on July 29, also held that the expenditure incurred by [...] Full Article