withholding tax

Kalpesh (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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