Payment for transfer of right to use software loaded on hardware – not royalty

Payment for transfer of right to use software loaded on hardware – not a royalty; Making available other personnel to subsidiary under control and supervision – constitutes Service PE.

Background
Lucent Technologies International Inc. 1(“the assessee”) is a company incorporated in the USA. It is a tax resident of USA. It is a leading supplier of hardware and software used for GSM cellular radio telephone system. The assessee had supplied telecommun

Please become a Premium member. If you are already a Premium member, login here to access the full content.