https://www.taxtmi.com/highlights?id=56950 Management Service Agreement ("MSA") to its subsidiaries - the majority of the services are technical in nature and the remaining one are in the area of consultancy. Therefore, we cannot agree with the submission that they were only managerial in nature and not in the nature of technical or consultancy services. - However, only "direct technical advice, support and management including implementation" service provided under Information Technology (IT) service meets the requirement Of 'make available' in clause (c) of Article 13.4 under the treaty. Therefore, only this particular service is found to be in the nature of "fee for technical services" under Article 13.4(c) of India-UK Tax Treaty. - AAR en-us Mon, 01 Mar 2021 10:23:49 +0530 Mon, 01 Mar 2021 10:23:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=56950 Management Service Agreement ("MSA") to its subsidiaries - the majority of the services are technical in nature and the remaining one are in the area of consultancy. Therefore, we cannot agree with the submission that they were only managerial in nature and not in the nature of technical or consultancy services. - However, only "direct technical advice, support and management including implementation" service provided under Information Technology (IT) service meets the requirement Of 'make available' in clause (c) of Article 13.4 under the treaty. Therefore, only this particular service is found to be in the nature of "fee for technical services" under Article 13.4(c) of India-UK Tax Treaty. - AAR Highlights Income Tax Mon, 01 Mar 2021 10:23:49 +0530 https://www.taxtmi.com/highlights?id=56950