https://www.taxtmi.com/caselaws?id=262219 Under the amended India-UK Tax Treaty, managerial services fall outside fees for technical services, and technical or consultancy services are taxable only if they make available technical knowledge, experience, skill, know-how or processes. Review, supervision, guidance, monitoring, human resource support, target-setting and performance appraisal under Agreement No. 1 were treated as routine managerial functions, while procurement support under Agreement No. 2 was found to be commercial sourcing assistance without transfer of know-how. The receipts under both agreements were therefore not taxable in India as fees for technical services. The royalty alternative was rejected because no intellectual property or proprietary information was transferred, and service permanent establishment was not established on the record. en-us Wed, 29 Jul 2015 00:00:00 +0530 Sat, 07 Nov 2015 15:21:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=262219 Under the amended India-UK Tax Treaty, managerial services fall outside fees for technical services, and technical or consultancy services are taxable only if they make available technical knowledge, experience, skill, know-how or processes. Review, supervision, guidance, monitoring, human resource support, target-setting and performance appraisal under Agreement No. 1 were treated as routine managerial functions, while procurement support under Agreement No. 2 was found to be commercial sourcing assistance without transfer of know-how. The receipts under both agreements were therefore not taxable in India as fees for technical services. The royalty alternative was rejected because no intellectual property or proprietary information was transferred, and service permanent establishment was not established on the record. Case-Laws Income Tax Wed, 29 Jul 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=262219