Advisory services is technical services under Article 13.4 of India-French DTAC

Managerial and consultancy services provided by a French company are ‘made available’ to the Indian company and therefore taxable as Fees for Technical Services in spite of Most Favoured Nation clause under the India-France tax treaty As regards consultancy services, the question is whether such services are made available in the context of the DTAC between India and France read with the DTAC between India and US relied on by the applicant. It is seen that the advice and assistance rendered by the French Company to the applicant are not transient in nature and are capable of being used by ...