Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
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Taxability of Fees for technical services (FTS) - In Article–13(4)(c) of the India–UK tax treaty the words “or consists of the development and transfer of a technical plan or technical design”, appearing in the second limb has to be read in conjunction with “make available technical knowledge, experience, skill, knowhow or processes” - since technical design/drawings/plans supplied by the assessee cannot be used by the Indian entity in any other project in future same is not FTS taxable in India
Taxability of Fees for technical services (FTS) - In Article–13(4)(c) of the India–UK tax treaty the words “or consists of the development and transfer of a technical plan or technical design”, appearing in the second limb has to be read in conjunction with “make available technical knowledge, experience, skill, knowhow or processes” - since technical design/drawings/plans supplied by the assessee cannot be used by the Indian entity in any other project in future same is not FTS taxable in India
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