Service fees paid to subsidiary for product promotion under treaty with Russia
The Authority for Advance Ruling (AAR) determined that payments of service fees for product promotion services cannot be categorized as “fees for technical services” under the India-Russia income tax treaty or under the provisions India’s tax law. Accordingly, the payments are not subject to tax withholding. The case is: Dr. Reddy Laboratories Limited. Read KPMG September 2016 report [PDF 343 KB]