https://www.taxtmi.com/circulars?id=4552 Payments under technical collaboration agreements must be analysed to determine whether they constitute payment for temporary use of technical knowledge or patents (revenue), supply of defined services, or acquisition of an asset or enduring advantage (capital). Tax treatment of the foreign recipient depends on whether the receipt is capital or revenue, whether services were rendered in India or abroad, and whether amounts constitute royalty; consolidated or sales-linked payments must be objectively allocated among these elements. Payers may seek advance determination of the taxable proportion for withholding purposes. en-us Mon, 25 Nov 1974 00:00:00 +0530 Wed, 30 Jul 2008 14:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/circulars?id=4552 Payments under technical collaboration agreements must be analysed to determine whether they constitute payment for temporary use of technical knowledge or patents (revenue), supply of defined services, or acquisition of an asset or enduring advantage (capital). Tax treatment of the foreign recipient depends on whether the receipt is capital or revenue, whether services were rendered in India or abroad, and whether amounts constitute royalty; consolidated or sales-linked payments must be objectively allocated among these elements. Payers may seek advance determination of the taxable proportion for withholding purposes. Circulars Income Tax Mon, 25 Nov 1974 00:00:00 +0530 https://www.taxtmi.com/circulars?id=4552