Mere reimbursement of costs based on a cost sharing agreement not liable to withholding tax

Facts

• ABB Limited, an Indian company (ABB India) and ABB Research Limited, Zurich, a Swiss company (ABB Zurich) are part of the ABB group. The group is engaged in the manufacturing of power products and systems technologies and has business activities across the globe in over 100 countries.
• As a cost reduction strategy, all the basic research and development (R&D) for the ABB Group is coordinated and directed through ABB Zurich.
• ABB group entities who wish to participate in the basic R&D have to enter into a Cost Contribution Agreement (CCA) with ABB Zurich. ABB India is proposing to enter into CCA with ABB Zurich.

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