Payment for procurement of support services from foreign affiliate not liable to tax in India

Court : Authority for Advanced Ruling (AAR) Citation : Bharti AXA General Insurance Corporation Ltd. (2010-TII-30-ARA-INTL) (AAR) Brief : Authority for Advanced Ruling (AAR) held that payment for procurement of support services vis-a-vis business, marketing, information technology and strategy from foreign affiliate company are not Fees for Technical Services (FTS) and royalty within the meaning of Article 12 of the India-Singapore tax treaty (tax treaty). Further, in the absence of Permanent Establishment of the foreign affiliate in India, the payment received by it cannot be taxed as busines...