In the absence of an FTS clause, Thai company’s technical receipts are non-taxable business profits without an Indian PE.
In the absence of an FTS clause, Thai company’s technical receipts are non-taxable business profits without an Indian PE. Issue Whether, in the absence of a specific Fees for Technical Services (FTS) clause in the India-Thailand DTAA, payments received by a Thai resident company from Indian group entities for management and technical services can be… Read More »