Ancillary software licensing services followed existing treaty precedent, leaving no substantial legal question for reconsideration.

Ancillary-service receipts connected with software licensing are discussed under the applicable tax treaty's fees-for-technical-services provisions. The analysis states that the Tribunal's treatment followed an existing precedent on software licence transactions, which had also governed the preceding assessment year and whose review was dismissed. As no distinguishing basis for reconsideration was identified, the notes record that no substantial question of law arose and that the Tribunal's treatment of the receipts stood in favour of the assessee.

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Issues: Whether receipts from ancillary services connected with software licensing were taxable as fees for technical services under the applicable tax treaty, and whether any substantial question of law arose from the Tribunal's decision.

Analysis: The Tribunal's treatment of the ancillary-service receipts was governed by the precedent concerning software licence transactions. The identical issue for the preceding assessment year had already been disposed of on the basis of that precedent, whose review had also been dismissed. No distinguishing basis warranting reconsideration was shown.

Conclusion: No substantial question of law arose; the Tribunal's treatment of the receipts was sustained, in favour of the assessee.

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