https://www.taxtmi.com/article/detailed?id=6184 Characterisation of cross-border payments under section 195 hinges on whether receipts are royalty, business profits, or Fees for Technical Services. Critical determinants include copyright versus copyrighted article, severability of sale and services, treaty language, and the make available requirement for technology transfer. Installation may qualify as assembly and be excluded from FTS; training and retained proprietary rights can attract FTS. Reimbursements are non taxable only if genuine cost pass throughs without profit or transfer of proprietary rights. Contract drafting and documentary evidence govern withholding obligations and timing of taxability. en-us Tue, 31 Mar 2015 05:56:28 +0530 Wed, 01 Apr 2015 09:42:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/article/detailed?id=6184 Characterisation of cross-border payments under section 195 hinges on whether receipts are royalty, business profits, or Fees for Technical Services. Critical determinants include copyright versus copyrighted article, severability of sale and services, treaty language, and the make available requirement for technology transfer. Installation may qualify as assembly and be excluded from FTS; training and retained proprietary rights can attract FTS. Reimbursements are non taxable only if genuine cost pass throughs without profit or transfer of proprietary rights. Contract drafting and documentary evidence govern withholding obligations and timing of taxability. Articles Income Tax Tue, 31 Mar 2015 05:56:28 +0530 https://www.taxtmi.com/article/detailed?id=6184