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Whether income from referral services amount to fees for technical services – whether in absence of a PE, same could be taxed in India
Case Law Details
- Case Name
- Re. Real Resourcing Limited (Authority for Advance Rulings)
- Appeal Number
- Only available for paid members
- Courts
- Advance Rulings
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AAR Ruling: Referral fee received from an Indian based recruitment agency by a non-resident is not liable to tax in India in view of the provisions of India-UK Double Taxation Avoidance Agreement [Real Resourcing Limited (AAR No. 828 of 2009)].
Facts:
Real Resourcing Limited (applicant), a company incorporated in United Kingdom (UK), was a tax resident of UK. The applicant proposed to render the following services in India:
Recruitment services where the applicant would place a candidate with an Indian company;
Referral services where the applicant would refer potential Indian clients to th...
