https://www.taxtmi.com/caselaws?id=264289 The article explains that management service fees described as managerial, commercial, marketing, administrative and support services were analysed under the India-Sweden treaty in light of its protocol and the most favoured nation clause. It notes that the protocol was treated as operative so that the more restrictive India-Portugal treaty standard applied, requiring the services to make available technical knowledge, skill, know-how or processes before they could be taxed as fees for technical services. On that basis, mere rendering of managerial services without satisfying the make available condition was treated as insufficient for Indian taxability. en-us Fri, 22 May 2015 00:00:00 +0530 Tue, 22 Sep 2015 06:54:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=264289 The article explains that management service fees described as managerial, commercial, marketing, administrative and support services were analysed under the India-Sweden treaty in light of its protocol and the most favoured nation clause. It notes that the protocol was treated as operative so that the more restrictive India-Portugal treaty standard applied, requiring the services to make available technical knowledge, skill, know-how or processes before they could be taxed as fees for technical services. On that basis, mere rendering of managerial services without satisfying the make available condition was treated as insufficient for Indian taxability. Case-Laws Income Tax Fri, 22 May 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=264289