India- Ireland DTAA: Transfer of exclusive rights of copyright in computer software, not mandatory to classify receipts as royalty: AAR

In re Skill Soft Ireland Limited (Authority for Advance Rulings) Brief of the Case Authority for Advance Rulings held In the case of SkillSoft Ireland limited that in the case of Synopsis International Old Ltd. 212 TAXMAN 454 (Kar), high court held that merely because the words non-exclusive and non-transferrable are used in the license agreement, it does not take away the software out of definition of copyright. It was further held that even if it is not transfer of exclusive right in the copyright, the right to use the confidential information embedded in the software in terms of the afores...