Approval of composite agreements for tax exemption under the Income tax Act, with apportioned disallowance for non qualifying items. Approval of composite agreements will be granted subject to apportionment between qualifying technical know how components and non qualifying items. The tax authority will consider the totality of the agreement and allow exemption for that portion of royalty, commission or fees attributable to provision of technical know how or related services after making a suitable disallowance for non qualifying elements.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Approval of composite agreements for tax exemption under the Income tax Act, with apportioned disallowance for non qualifying items.
Approval of composite agreements will be granted subject to apportionment between qualifying technical know how components and non qualifying items. The tax authority will consider the totality of the agreement and allow exemption for that portion of royalty, commission or fees attributable to provision of technical know how or related services after making a suitable disallowance for non qualifying elements.
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