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withholding tax

(Querist) 17 September 2008 This query is : Resolved 
Could you please let me know on your view applicability of withholding tax on following transaction:
Payment of guarantee issuance charges by branch in India to HO in France .
Payment of fees for arrangement for ECB by branch in India to HO in France
Whether this payment could be considered as FTS and tax @ 10% should be withheld as per India France tax treaty.
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Guest (Expert) 17 September 2008
It has to be witheld, the moment you say it is TS if it is other service then 30%

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