WITHHOLDING TAXES-CROSS BORDER ISSUES

WITHHOLDING TAXES-CROSS BORDER ISSUES
CREDIT OF TAXES AND WITHHOLDING TAXES-CROSS BORDER ISSUES SUSHIL LAKHANI

PROFESSOR KLAUS VOGEL APPRECIATES THE INDIAN JUDICIARY FOR DECISIONS ON INTERNATIONAL TAXATION - ESPECIALLY THE DELHI SPECIAL BENCH DECISION IN THE CASE OF NOKIA, ERICCSON AND MOTOROLA – ECONOMIC TIMES OF 7TH APRIL 2006

Cross Border Payments-Withholding Tax Issues
PART - A Cross Border Payments-Withholding Tax Issues IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

Cross Border Payments Withholding Tax Issues-
PART - A Section 195 (1) – Scope of the section any person responsible for paying to a non-resident or a foreign company Non resident to non resident covered. Payment by Branch to HO (ABN Amro Bank (280 ITR (AT) 117)(Kol – SB)) “sum chargeable to tax (other than Salaries)” Capital Gains – NR to NR trf of shares?? Sec 195 vs Sec 196D?? (Int to FIIs) Interest – whether all interest or only interest chargeable to tax covered?? Gift?? Gross Sum vs Income element FTS, Royalty etc Other than Sec 44D IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - A Section 195 (1) – Scope of the section Treaty vs Act meaning of “Liable to Tax” – Recent developments Abdul Razak Meman (276 ITR 306)(AAR) GE Pension Trust (280 ITR 425) (AAR) Green Emirates Shipping and Travel (99 TTJ 988) (Mum) Surcharge and Education Cess not to be included when treaty applied . IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - A Section 195A – Grossing up of tax Deductibility of TDS borne by payer--S.40(a)(ii)?? Sec 40(a) (ii) “any sum paid on account of any rate or tax levied on the profits or gains of any business or profession or assessed at a proportion of, or otherwise on the basis of, any such profits or gains” Incidental issues Expenses whether disallowed u/s 40(a)(i), if TDS partly deducted?? IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - A Certificate by a CA for remittance: Clause 1 – “name & address of beneficiary” “Beneficiary” – meaning of – “Beneficial Owner” or “Recipient”? Clause 7– determination of a PE and profits of PE: Whether CA duty bound to ascertain the existence of PE? Determination of “attributable to PE” ? IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - A Certificate by a CA for remittance: Some Issues: Consequence of difference of opinion between a CA and AO Consequence of change in the view due to an amendment or a judicial decision or circular subsequent to issue of certificate. Determination of any “special relation” between payer and payee. Tax residency certificate – if not available? Tax residency certificate—not sufficient -- dual residency? Validity period of tax residency certificate / undertaking / declaration from the payee – for a year or for single payment? IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - A Certificate by a CA for remittance: Some Issues (Cont…): Whether CA certificate is an alternative to Order u/s 195(2)? “Non resident” status of the receiver – at what point of time to be considered? at the time of signing of agreement or the prior financial year or making of remittance In absence of address in the agreement is the payer obliged to determine the status of purchaser for purchase of capital gains? IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - A SECTION 9(1)(i)--BUSINESS CONNECTION Taxable only if : relates to a source of income or asset in India; or if “business connection” under IT Act and “PE” under the treaty exists. Taxable only to the extent “reasonably attributable” to operations in India. Specific exclusions – Explanation 1(b); 1(c) & 1(d) of Section 9(1)(i) Specific inclusions – Explanation 2 to Section 9(1)(i) treaty concept of dependent agent introduced in Act agent need not be in India but must Act in India. IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - A SECTION 9(1)(i)--BUSINESS CONNECTION Section 9(1)(i) – Business Connection – Judicial Interpretations CIT Vs. R.D. Aggarwal & Co. (56 ITR 20) & Circular 23 and 786 lay down certain tests. Business in India Vs. Business with India Difference between a BC and a PE BC is wider in scope than PE. IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - A SECTION 9(1)(i)--BUSINESS CONNECTION - Issues Source of Income outside India “Source” – meaning of (91 ITD 133(Del); 85 ITD 478(Del)) Whether “Export” – a source outside India ??(262 ITR 513(Mad)) “Service utilised” is where the income accrues (250 ITR 164(AP)) Query? Fees to Investment Advisor of non- resident FII--both are outside : No presence of adviser in India (250 ITR 194(AAR); 271 ITR 1 (AAR); 272 ITR 416 (AAR)) Presence of adviser in India – Service PE clause Payment of commission to foreign agents (Circular 23 of 1969; 125 ITR 525(SC); contrary ITR 97(AAR)) IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - A SECTION 9(1)(i)--BUSINESS CONNECTION - Issues Payments for supply and installation of equipment Payment of design and drawings alongwith equipment (259 ITR 248)(Del)-Mitsui); Payment for installation and supervision of machinery supplied—not taxable --as part of supply(262 ITR 110(AP)-Sundwiger) ; Contrary Decisions: Proportionate amount relating to provision of certain subsidiary services in course of supply taxable as PE existed.– Protocol of India – Japan Treaty (271 ITR 193)(AAR)-IHH) Where consideration for supply and installation separately stated (279 ITR 165)(AAR)-Rotem) Finalisation and signing of deal by country manager in India amounts to PE (268 ITR 156)(AAR)-Sutron) IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - A ROYALTIES Royalty and FTS deemed to accrue or arise in India if payable by: In all cases without exception Government In all cases, except where payable for any right, property etc. or services utilized for the purpose of / in business or profession carried on by such person outside India, or for the purposes of making or earning any income from any source outside India Resident Only in cases where it is payable for any right, property etc. or services utilized for the purpose of a business or profession carried on by such person in India, or for the purposes of making or earning any income from any source in India Non-resident IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - A ROYALTIES For Agreements on or after 1 April 2003 No PE in India Section 115A of the Act Taxed on gross basis Lower rate for Central Government approved Agreements or those relating to matter included in Industrial Policy 20% for agreements entered before 1 June 2005 10% for agreements entered on or after 1 June 2005 Provisions earlier applicable only to foreign companies extended to all non-resident entities w.e.f. AY IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - A ROYALTIES For Agreements on or after 1 April 2003 PE in India and Royalty / FTS effectively connected with such PE Section 44DA of the Act w.e.f. AY Taxed on net basis at the rate applicable to Non Residents Amounts paid to Head Office / Other Offices not deductible (except reimbursement of actual expenses) PE as defined in Section 92F(iiia) of the Act – fixed place PE IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - A ROYALTIES Difference in definition of Royalty under Act and Treaties ACT TREATY(UN Model) Consideration for transfer Consideration for use or of “all” of any rights right to use “Cinematographic films” “Cinematographic specifically excluded films” included Services in relation to Services in relation to transfer of any rights transfer if incidental will covered get covered here else not Use of equipment in No Such exclusion. Use of connection with exploration all sorts of equipment of mineral Oil excluded covered. IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - A ROYALTIES Payment for Software Off- the -shelf Software ; (94 ITD 91 (Bang.-Samsung)); ( TCS-SC-271 ITR 401) Customised Software; ( 88 ITD 134(Mum)—ISBC) Software along with Hardware (82 TTJ 163-Bang-Lucent) IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - A ROYALTIES Payment for following whether “Royalty” ? Consideration for design and drawings (Indian Hotels (Unreported) Payment for “Know how” and “Information” Payment for access to info base-not royalty (94 ITD 9 (Bang)-Wipro) Payment for the use of satellite (78 TTJ 498 (Del)-Asiasat) IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - A ROYALTIES Analysis of some treaties signed by India Excludes Ships and Aircrafts UK USA Exclude ICS equipment from ambit of Royalties Belgium / France / Greece / Israel / Netherlands / Sweden Excludes payment for use of Aircraft Ireland Includes proceeds from outright sale of copyrights etc. that are contingent on its use by purchaser USA IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - A Fees For Technical Services (FTS) FTS receipt taxable in India regardless of situs and mode of services – other than FTS utilised in a business or source outside India. Consideration (includes lump sum consideration) for rendering any: Managerial, technical or consultancy services Thrust is on ‘Services’ Technical Services vs Technology driven services IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - A Fees For Technical Services (FTS) Excludes: Construction, Assembly, Mining, Any like project, Income chargeable as salaries, IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - A SOME ISSUES IN FTS Connectivity payments –standard facilities (80 TTJ 191 (Bang)- Wipro) Payment for use of telephone, electricity etc i.e. standardised products is not FTS (251 ITR 53)(Mad)-Skycell Payment for repairs Hardware (273 ITR 437)(AAR)-Airport Authority-Not FIS Software – Clause 12 (4) (a) of India USA Treaty – Ancillary and subsidiary to royalty (273 ITR 437)(AAR)-Airport Authority Specialised repairs –FTS (79 TTJ 268) (Del)-Sahara General repairs-Not FTS (91 ITD 133)(Del)-Lufthansa IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - A Fees For Technical Services (FTS) Absence of specific Article on FTS Bangladesh, Brazil, Greece, Indonesia, Libya, Mauritius, Nepal, Philippines, Sri Lanka, Syria, Thailand, UAE, UAR Concurrent Coverage under Independent Personal Services (IPS) Japan, New Zealand IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - A Fees for Included Services (FIS) – “Make Available” Deals with Technical Services - but coverage is very narrow. Services under FIS should be technical (Mckinsey (99 TTJ 857)); and Services should satisfy further conditions as per the MOU of India –US Treaty IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - A Fees for Included Services (FIS) – “Make Available” (Cont…) Associated with Service PE The words “make available” held to have the same meaning as in India-USA Treaty even in absence of the MOU (Raymonds Ltd. (80 TTJ 120)) Caution! These treaties also have “Service PE” clause. IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - A Fees for Included Services (FIS) – “Make Available” (Cont…) Case Laws Advisory service –not FIS (80 TTJ 806) (Cal)-Raymonds Preparation of project report-FIS?? (85 TTJ 794)(Del)-Sinar Mas Payment for strategic consultancy services-Not FIS (99 TTJ 857)(Mum) Mckinsey Payment for testing charges-FIS (278 ITR 233)(AAR); (278 ITR 97)(AAR) Analysis of few Treaties signed by India (FIS) Directly - Australia, Canada, Cyprus, Malta, Portugal, Finland, Singapore, USA, UK Due to MFN Clause - Belgium, France, Israel, Kazakhstan, Spain, Sweden—(Service PE missing) IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - A Reimbursement of expenses Reimbursement of incidental expenses in addition to payments of Fees for Technical Services (FTS) / Royalty Reimbursement of cost of services of a third party engaged by the non-resident. (278 ITR 97)(AAR) -Wallace Reimbursement of allocated cost (i.e. costs- sharing arrangements) (268 ITR 1)(AAR)-Danfoss Payments for services rendered at cost. (273 ITR 67)(AAR)-Timkin Reimbursement of living allowance, etc of a person deputed to India by the non-resident. (274 ITR 261)(Del) Direct payments by the non-resident of expenses and salaries of foreign technicians. (233 ITR 751)(All) IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - A Reimbursement of expenses (Cont…) GREY AREAS Reimbursement of expenses incurred by group company outside India on behalf of Indian company If the services are taxable in India and If the services are not taxable in India Reimbursement of pre joint venture expenses like incorporation, registration fees etc. incurred by a foreign joint venture partner. IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - A INTEREST AND SHIPPING INCOME Analysis of some treaties signed by India: “interest on deferred payment sales” included in the definition – Indonesia, Philippines Penalty charges for later payment excluded – Singapore, Indonesia Payment of usance interest is not a part of purchase price (261 ITR 113) (Guj) IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - A INTEREST AND SHIPPING INCOME Payments for Shipping: Freight Payment to Shipping Agent (Circuar 742) Bare Boat lease (113 ITR 307)(SC) Wet Lease – is same as bare boat lease – sec 44B does not apply (4 SOT 18) Analysis of Treaties signed by India Profits taxable only in residence country – USA, Singapore Profits taxable where effective management is situated – Profits taxable in India for specified no of years – Netherland, Japan Profits taxable in Indian but at concessional rates - IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

Cross Border Payments – Credit of Taxes
PART - B Cross Border Payments – Credit of Taxes IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - B EXEMPTION METHOD Full Exemption Exemption with progression – taken into account for rate purposes CREDIT METHOD Full credit – No restriction Ordinary credit – restricted to the extent of tax payable – qua “Income” Underlying tax credit – except Mauritius & Singapore Treaty only one way in Indian Treaties Tax sparing Sparing w.r.f. certain income Sparing w.r.f. tax payable (e.g. Mauritius) IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - B Underlying Tax Credit Directly Via Mauritius UK Parent / Home Company Income (Grossed up) 30% Underlying Tax Credit (633) 1,633 (490) Underlying Tax Credit 1,143 490 245 1,388 Offshore Intermediary Company 15% Withholding Tax (245) NIL Indian Host Company 12.5% (143) 1,000 IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - B General Principles Whenever exemption method is followed – the expenses are also not deductible. Grossing up of Underlying Tax & Dividend Distribution Tax. No Grossing up of Tax Sparing as no tax has been paid. IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - B Case Studies for Group Discussion: Case Study (a) Facts: “X” (Parent Company in India) “Z” (100% Subsidiary in Mauritius) “A” (50% Subsidiary in BVI) IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - B Case Study (a) Contd. (i) What is the “Mauritius Tax payable” ?? As per (Article 23(3) of the India - Mauritius Treaty) “Mauritius tax payable” shall be deemed to include any amount which would have been payable as Mauritius tax for any year but for an exemption or reduction of tax granted for that year or any part thereof under: (i) section 33, 34, 34A and 34B of the Mauritius Income – tax Act, 1974 (41 of 1974) any other provision which may be subsequently be made granting an exemption or reduction of tax which the competent authorities of the contracting states agree to be for the purposes of economic development. IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - B Case Study (a) Contd. (ii) Will ‘X’ be entitled to a foreign tax credit in India for the taxes payable (before Tax Sparing) in Mauritius ?? Article 23(3)(i) of India Mauritius Treaty – Section 33, 34, 34A and 34B of the Mauritius Income Tax Act, 1974 have been deleted – Article 2(2) has ambulatory approach – Similar taxes which are imposed after the date of conventions are also covered. Therefore ‘X’ Should be entitled to credit of taxes payable in Mauritius though the taxes are not paid because of Tax Sparing Clause in Article 23(3). IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - B Case Study (a) Contd. (iii)Whether change in the character of income makes a difference for credit?? The Residence State is obliged to give credit / exempt on income so long as the source state has taxed that item “in accordance with provision of the convention.” (Para 32 of OECD Commentary on Article 23) IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - B Case Study (b) Whether Exchange Rate fluctuation should be considered for giving credit ?? Rate of exchange for conversion into rupees of income expressed in foreign currency. (Rule 115 of the Income Tax Rules 1962) Telegraphic Transfer buying Rate of such currency as on the specified date. (31 ITR 538 (Ch. D)) IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - B Case Study (c) Whether foreign tax credit can be denied on the ground that the taxes are not paid by the foreign deductor to the Govt. of foreign country ?? No ?? (104 ITR 233(Guj)) IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

Case studies on withholding of taxes
PART - C Case studies on withholding of taxes IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - C Case Study 1: Whether PH can claim refund or US Co will have to claim refund? Circular 790 dated Whether the two instances in the Circular are only illustrative? 83 TTJ 458 (mum)(TELCO) – if assessee was not liable to deduct tax it can claim refund if TDS certificate not issued Will the answer be different if the TDS certificate is issued? Yes. Not entitled to claim refund (82 TTJ 325(Del)) If the tax was borne by PH, whether that would make a difference? No if certificate has been issued?? IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - C Case Study 1: (Cont…) What is the obligation of PH for issue of TDS Certificate. Certificate has to be issued within 30 days of credit of deduction of tax (Rule 31) 5 Whether excess deduction u/s 195 in one quarter can be adjusted against short deduction u/s 195 in next quarter? Yes Quarterly return to be filed in Form 27 6 Whether excess deduction u/s 195 can be adjusted against payment of TDS u/s 194A to 194D? No restrictions under the Act IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - C Case Study 2: Whether payments for business information will amount to FTS in India and hence liability to TDS? Non Technical Services – not FIS (99 TTJ 857-Mckinsey) Whether application u/s. 195(2) mandatory? No Payer should apply only when he is unable to determine the sum chargeable to tax IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - C Case Study 2: 3 Whether the AO was justified in disallowing the payments u/s. 40(a)(i)? Yes?, if he is of the view that TDS was deductible (Sol Pharma (83 ITD 72 (Hyd)) Appeal can be filed against such an addition Fact that in the assessment of Exotic USA the income was not taxable can of help in getting a favourable order but that by itself not enough. IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - C Case Study 3: Whether payment by a non resident to another non resident in respect of shares in Indian company is chargeable to TDS? Yes; Difficult for the Department to enforce . If Yes, Whether Canada Ltd. should consider the details of different shareholders before deducting tax? Yes Indexation not available (Section 48) What is the rate of tax applicable to : Resident Shareholders – No TDS Ismail (UAE) – (Green Emirates Vs.Meman) Not deductible- As per India UAE Treaty gains taxable only in UAE, hence not deductible. IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - C Case Study 3: (Cont…) Charlie (Mauritius) – Not deductible. As per India Mauritius Treaty gains taxable only in Mauritius, hence not deductible. Dinanath (NRI) Section 115E TDS on LTCG – 10% TDS on STCG – 10% Other non-residents (Assumed to be resident of USA) TDS on STCG – 10 % Sub account of foreign FII No TDS – Sec 196D (2) IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - C Case Study 4: Whether tax is deductible on payment for purchase of software? No --as purchase of software not royalty if copyrights not transferred. Assuming payment for purchase of software is royalty, whether TDS is deductible when: Payment of Rs 5 Cr is made to Software Ltd – Yes Payment of Rs. 5 Cr is made to Singapore Ltd –Yes? Payment of Rs. 5 Cr is made by Singapore Ltd to Software Ltd – Yes?? Sec 9(1)(vi)(c) – “a person who is a non resident …for the purpose of business or profession carried on by such person in India” IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - C Case Study 5: ‘A’ Ltd. Project of ‘A’ Ltd.
Contract to supply Personnels ‘A’ Ltd. ‘B’ Ltd. - HR Agency Contract to appoint persons at Project Cost of persons + 10% of fees In India Outside India Project of ‘A’ Ltd. Appointment of qualified persons ‘C’ Inc. – Wholly owned subsidiary IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - C Case Study 5: 1 Is TDS u/s 195 deductible on payments made by B Ltd. to C Inc in respect of Cost of the person employed and 10% fees? TDS deductible on both cost of the person and 10% fees charged 278 ITR 97 (AAR)-Wallace and Timkin( 273 ITR 67 AAR) IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - C Case Study 6: 1 What will be the tax to be deducted at source for payment of “Professional Fees” paid to Individual? Covered under S 9(1)(vii) Treaty--Specific Provision (IPS) overrides general provision (FIS) Covered under IPS of India- USA Treaty Fixed base or 60 days in the source state If does not fit in “Professional Services” of IPS Article – Article 5 (PE) applies. No TDS IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

PART - C Case Study 7: Whether payment for roaming charges is “royalty”? – No Service (E-Commerce report of OECD) vs use of equipment Technical Services vs Technology driven services (Wipro (80 TTJ 191 Bang); Skycell (251 ITR 53 Mad)) IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

THANK YOU IFA-RRC - April, 2006 Cross Border Payments Withholding Tax Issues- Cross Border Issues

WITHHOLDING TAXES-CROSS BORDER ISSUES

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