Brokerage commission benchmarking and investment advisory comparability depend on functional differences, economic circumstances and the services prov...
Infrastructure and central support-service cost recharges do not qualify as technical service fees under the India-UK DTAA solely because the services involve professional expertise or confer commercial benefits. Article 13(4)(c) requires technical knowledge, experience, skill, know-how or processes to be made available for independent application by the recipient, or a technical plan or design to be developed and transferred. The analysis applies where the services are as claimed and do not involve distinct technical services or transfers of technical know-how beyond the scope of the applicable precedent. The India-US DTAA also informs the make-available analysis.
Infrastructure and central support-service cost recharges do not qualify as technical service fees under the India-UK DTAA solely because the services involve professional expertise or confer commercial benefits. Article 13(4)(c) requires technical knowledge, experience, skill, know-how or processes to be made available for independent application by the recipient, or a technical plan or design to be developed and transferred. The analysis applies where the services are as claimed and do not involve distinct technical services or transfers of technical know-how beyond the scope of the applicable precedent. The India-US DTAA also informs the make-available analysis.
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