Recent Delhi ITAT Ruling on Taxability of Salary Reimbursements in Employee Secondment Arrangements
The Delhi ITAT recently ruled that salary reimbursements made under a secondment arrangement cannot automatically be treated as Fees for Technical Services (FTS). In the Honda R&D case, the Tribunal emphasised that where seconded employees work under the control and supervision of the Indian entity, cost-to-cost salary reimbursements may retain their character as salary costs rather than taxable technical service fees. The ruling offers important guidance for multinational organisations managing cross-border employee deployments and global mobility programmes.



















