https://www.taxtmi.com/caselaws?id=285506 Under the India-Netherlands DTAA, limited network access and use of software for internal service delivery did not amount to royalty because no right to reproduce, exploit, assign, or otherwise use the underlying copyright was transferred; the receipts were therefore not taxable as royalty. IT support receipts also did not constitute fees for technical services because the services did not "make available" technical knowledge, experience, skill, know-how, or processes to the recipient for independent future use; the receipts were therefore outside Article 13(4)(c). The additions treating both categories of receipts as taxable were deleted. en-us Thu, 16 Nov 2017 00:00:00 +0530 Thu, 16 Jan 2020 11:00:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=285506 Under the India-Netherlands DTAA, limited network access and use of software for internal service delivery did not amount to royalty because no right to reproduce, exploit, assign, or otherwise use the underlying copyright was transferred; the receipts were therefore not taxable as royalty. IT support receipts also did not constitute fees for technical services because the services did not "make available" technical knowledge, experience, skill, know-how, or processes to the recipient for independent future use; the receipts were therefore outside Article 13(4)(c). The additions treating both categories of receipts as taxable were deleted. Case-Laws Income Tax Thu, 16 Nov 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=285506