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A Spanish company sought clarification on whether, due to the most-favoured-nation clause, it could apply a 10% withholding rate or an exemption to payments for technical services made to its parent company in India. The DGT ruled that the maximum rate is 10%, but rejected a reduction in the scope of the technical services concept.
Question raised: Whether, by virtue of the most-favored-nation clause, a withholding tax rate of 10% would be applicable (instead of the 20% set forth in the Convention), or even a total exemption from withholding if it were understood that a reduction in the scope provided in the convention regarding the concept of technical services has occurred.
In application of the most-favored-nation clause of the Convention between Spain and India, the maximum withholding tax rate for payments for technical services may not exceed 10%, as India has treaties with third States establishing said percentage. However, it is not possible to apply a more reduced scope of application for the concept of technical services, as the Indian authorities are reviewing this concept and its scope has not been clarified through mutual agreement procedure.
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