S. 195 -Reimbursement of Salary to Overseas Parent Company attracts TDS

Tax ability of payments made to overseas group companies under  secondment arrangement – AAR It was held that personnel seconded to the Taxpayer, a group company in India, did not become its employees in the absence of an obligation undertaken by the Taxpayer to pay employment costs of such personnel. This was held despite the fact that the Taxpayer exercised control and supervision and was also responsible for the work of the personnel. As employees continue to be the employees of the overseas entities and their employer continues to be the overseas entity concerned and employees are r...