Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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Taxability of income in India - Taxability as Royalty or FTS - The tribunal systematically addressed the taxability of each type of service. It concluded that the services provided did not qualify as royalty or FTS under the India-Netherlands tax treaty because they did not make any technology, knowledge, experience, or skills "available" to the Indian group companies in such a manner that would enable them to perform these services independently in the future. The tribunal relied heavily on judicial precedents and the specific provisions of the India-Netherlands tax treaty, notably the "make available" clause.
Taxability of income in India - Taxability as Royalty or FTS - The tribunal systematically addressed the taxability of each type of service. It concluded that the services provided did not qualify as royalty or FTS under the India-Netherlands tax treaty because they did not make any technology, knowledge, experience, or skills "available" to the Indian group companies in such a manner that would enable them to perform these services independently in the future. The tribunal relied heavily on judicial precedents and the specific provisions of the India-Netherlands tax treaty, notably the "make available" clause.
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