Case Law Details
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 enjoyment of the right, property or information for which a payment described in paragraph 3(a)* of this Article is received; or . .
Please become a Premium member. If you are already a Premium member, login here to access the full content.
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……