https://www.taxtmi.com/caselaws?id=334648 Management support, IT support and allied services rendered by a non-resident to its Indian group company were not fees for technical services under Article 13(4) of the India-Finland DTAA because the services did not make available technical knowledge, experience, skill, know-how or processes to the recipient. Mere technical input in performing the services was insufficient, and the services were found to be managerial and recurring without any transfer of technology or capability enabling the Indian entity to function independently. The receipts were therefore not taxable as fees for technical services under the treaty. en-us Fri, 14 Oct 2016 00:00:00 +0530 Thu, 17 Nov 2016 15:34:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=334648 Management support, IT support and allied services rendered by a non-resident to its Indian group company were not fees for technical services under Article 13(4) of the India-Finland DTAA because the services did not make available technical knowledge, experience, skill, know-how or processes to the recipient. Mere technical input in performing the services was insufficient, and the services were found to be managerial and recurring without any transfer of technology or capability enabling the Indian entity to function independently. The receipts were therefore not taxable as fees for technical services under the treaty. Case-Laws Income Tax Fri, 14 Oct 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=334648