Case Law Details
Case Name : M/s Dassault Systems K.K, In re. (Authority for Advance Rulings)
Related Assessment Year :
Courts :
Advance Rulings
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Authority for advance ruling recently held that payments received by the Applicant from its Indian reseller for supply of software products to end users should not be classified as royalty. The AAR further held that the relationship between the Applicant and the re seller does not create a permanent establishment (PE) for the Applicant under the agency rule. Hence, the payment should not be taxed in India under the provisions of the India-Japan Tax Treaty (Treaty).
Background and facts of the case
The Applicant, a company incorporated in Japan, is engaged in the business of providing software...
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Hello, have the laws concerning this article changed at all since written? I am getting pressure from my VAR for a situation which appears identical.
Thank you.