<h1>Indian Ruling: Subscription Fees to External Database Not Taxable as Royalty Without Permanent Establishment.</h1> The Authority for Advance Rulings determined that subscription fees paid by Indian subscribers to an external database service are not taxable as royalty or know-how in India. The service provides access to a copyrighted database but does not transfer any copyright rights. The fees are considered business income, taxable only if a Permanent Establishment (PE) exists in India. Currently, no PE is found, so the income is not taxable in India, and subscribers are not required to withhold tax. The ruling follows a similar decision in the case of a Spanish company.