Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
Employee stock-shortage penalties do not constitute consideration for services, preventing GST collection under Schedule II in employment relationship...
Treaty limitations on royalty taxation and the make-available condition restrict taxation of cross-border receipts despite transfer-pricing adjustments. Notional interest requires an invoice-wise factual basis and interest paid, credited, acknowledged as payable or made available; arm's-length recomputation cannot independently create interest taxable under the treaty. Standardised software supplied with restricted end-user rights, connectivity services without rights in equipment or processes, and lease rentals paid by a non-resident outside the treaty source rule do not constitute taxable royalty income. Testing, administrative reimbursements and non-technical managerial training are not fees for included services where they do not transmit independently usable technical capability. Non-residents are not liable for advance-tax interest for periods when deductible tax had to be excluded from advance-tax computation.
Treaty limitations on royalty taxation and the make-available condition restrict taxation of cross-border receipts despite transfer-pricing adjustments. Notional interest requires an invoice-wise factual basis and interest paid, credited, acknowledged as payable or made available; arm's-length recomputation cannot independently create interest taxable under the treaty. Standardised software supplied with restricted end-user rights, connectivity services without rights in equipment or processes, and lease rentals paid by a non-resident outside the treaty source rule do not constitute taxable royalty income. Testing, administrative reimbursements and non-technical managerial training are not fees for included services where they do not transmit independently usable technical capability. Non-residents are not liable for advance-tax interest for periods when deductible tax had to be excluded from advance-tax computation.
Note: It is a system-generated summary and is for quick reference only.