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Payments for technical services are to be treated as ‘fees for technical services’ under Article 13(4) of Indo-French DTAA
Case Law Details
- Case Name
- Maruti Udyog Ltd. Vs. ADIT (Int'l Taxation) [ITAT Delhi]
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2005- 2006
- Courts
- ITAT Delhi
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RELEVANT PARAGRAPH
9.1 Double Taxation Avoidance Agreement entered into between India and United Kingdom (206 ITR St. 235), Article 13(4) and 13(5) provides as. follows:
Article 13(4)
For the purposes of paragraph 2 of this Article, and subject to paragraph 5 of this Article, the term “fees for technical services” means payments of any kind to any person in consideration for the rendering of any technical or consultancy services (including the provision of services of technical or other personnel) which:
(a) are ancillary and subsidiary to the application or enjoym...
Dear sir,
Will you tell me URL which include;
Taxation of income of Non-residents from transfer of Technology – Tax treatment of Royalty and fees for technical Services
Contents
1 Rates of taxation
2 Exemptions from tax
3 Double tax Avoidance Agreements
8.1 Royalty has been defined to mean……