Payments received by a non-resident for Value Added Services (VAS) is partly treated as ‘Royalty’ and partly as ‘Fees for Technical Services’ under India-UK tax treaty

De Beers UK Limited Vs. DCIT (ITAT Mumbai)- The Tribunal held that the payment for VAS has to be considered partly as royalty under para 3(a) of Article 13 of the tax treaty being the payment for various types of information of commercial nature acquired based on past experience and partly as F

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