Salary Reimbursements to Foreign Head Office Not Taxable as FTS-AYesa Ingenieria Y Arquitectura S.A

In cross-border operations, salary payments to expatriate employees often pass through complex routing between an Indian branch and its foreign head office. This raises frequent disputes over whether such reimbursements should be taxed again as “fees for technical services” despite TDS already being deducted on salaries. A recent Delhi ITAT ruling clarifies this grey area, providing much-needed relief for multinational branches operating in India.