https://www.taxtmi.com/caselaws?id=382143 Software licence payments were treated as consideration for a copyrighted article, not for use of copyright, so they did not constitute royalty under section 9(1)(vi); the DTAA position prevailed because the treaty language had not changed. IT support and related connectivity charges were found not to be royalty and no technical services were made available. Lease line charges were characterised as use of data transmission facilities, or alternatively as reimbursement, so no withholding obligation arose. Web-based training fees were not fees for technical services in the absence of any transfer or making available of technical knowledge. Reimbursement of expatriate salaries did not attract withholding where tax had already been deducted on the salary component. en-us Mon, 24 Jun 2019 00:00:00 +0530 Wed, 26 Jun 2019 07:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=382143 Software licence payments were treated as consideration for a copyrighted article, not for use of copyright, so they did not constitute royalty under section 9(1)(vi); the DTAA position prevailed because the treaty language had not changed. IT support and related connectivity charges were found not to be royalty and no technical services were made available. Lease line charges were characterised as use of data transmission facilities, or alternatively as reimbursement, so no withholding obligation arose. Web-based training fees were not fees for technical services in the absence of any transfer or making available of technical knowledge. Reimbursement of expatriate salaries did not attract withholding where tax had already been deducted on the salary component. Case-Laws Income Tax Mon, 24 Jun 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=382143