https://www.taxtmi.com/caselaws?id=355548 Referral commission earned by a foreign branch for introducing an Indian client was not fees for technical services because the payment was consideration for referral activity, not for managerial, technical or consultancy services. The activity was performed outside India, the overseas branch had no permanent establishment in India, and the Indian branch played no role in the referral. On those facts, the receipt was not attributable to an Indian permanent establishment and fell within the treaty rules on business profits, so it was not taxable in India. en-us Fri, 09 Feb 2018 00:00:00 +0530 Fri, 10 May 2019 09:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=355548 Referral commission earned by a foreign branch for introducing an Indian client was not fees for technical services because the payment was consideration for referral activity, not for managerial, technical or consultancy services. The activity was performed outside India, the overseas branch had no permanent establishment in India, and the Indian branch played no role in the referral. On those facts, the receipt was not attributable to an Indian permanent establishment and fell within the treaty rules on business profits, so it was not taxable in India. Case-Laws Income Tax Fri, 09 Feb 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=355548