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Company not entitled to DTAA benefit since place of effective management located in a third country
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International Tax
Company not entitled to DTAA benefit since place of effective management located in a third country
Posted on
on
January 22, 2020
Tenet Tax Daily January 13 2020
By
tenettax-team
International Tax
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Loss making company for Transfer Pricing analysis to include companies declaring losses consistently for 3 consecutive AYs
Provision of BPO services does not create service PE and hence not taxable as per DTAA.
