https://www.taxtmi.com/caselaws?id=249863 Subscription revenue for access to a dealing-matching system was characterised as royalty under the India-UK DTAA and section 9(1)(vi) because subscribers received integrated access to the system, software, equipment and connectivity, including the ability to view, manipulate, create and redistribute data within contractual limits. The payment was treated as consideration for the use of, or right to use, commercial equipment, software and information, bringing it within the treaty royalty definition. Once characterised as royalty, the alternative arguments on fee for technical services and permanent establishment were treated as academic, and the revenue was held taxable as royalty. en-us Fri, 18 Jul 2014 00:00:00 +0530 Fri, 25 Jul 2014 10:38:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=249863 Subscription revenue for access to a dealing-matching system was characterised as royalty under the India-UK DTAA and section 9(1)(vi) because subscribers received integrated access to the system, software, equipment and connectivity, including the ability to view, manipulate, create and redistribute data within contractual limits. The payment was treated as consideration for the use of, or right to use, commercial equipment, software and information, bringing it within the treaty royalty definition. Once characterised as royalty, the alternative arguments on fee for technical services and permanent establishment were treated as academic, and the revenue was held taxable as royalty. Case-Laws Income Tax Fri, 18 Jul 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=249863