Subscription Fees for CRM Services Not Royalty or FTS under India-Singapore DTAA

CIT International Taxation Vs Salesforce. Com Singapore Pte. Ltd. (Delhi High Court) Delhi High Court has dismissed a batch of appeals filed by the tax authorities, affirming that the subscription fees received by Salesforce.com Singapore Pte. Ltd. for its Customer Relationship Management (CRM) software services do not constitute “royalty” income under either the India-Singapore Double Taxation Avoidance Agreement (DTAA) or the Indian Income Tax Act, 1961. The judgment, delivered on a common set of questions across multiple assessment years (2011-12 to 2017-18), upholds the earlier...