Advance Ruling – Payment for support service taxable as Fees for Technical service under India-Netherlands DTAA

Payment to be made by Perfetti India for the cost to be allocated by the applicant is taxable under Article 12.5(a) and as also under Article 12.5(b) of the DTAC between India and The Netherlands – AAR Re- Perfetti Van Melle Holding B.V., Netherlands (AAR) – Applicant seeks advance ruling on the following questions:- 1. On the facts and circumstances of the case whether the payment to be made by Perfetti Van Melle India Private Limited (‘Perfetti India’) for the cost to be allocated by Perfetti Van Melle Holding BV (‘the Applicant’) will not be taxable in India in the hands...