https://www.taxtmi.com/caselaws?id=295139 Subscription receipts for access to an online scientific database were characterised as consideration for access to copyrighted material, not for use of or right to use copyright. The arrangement granted only non-exclusive, non-transferable user access to search, browse, view, print and store material for personal use, while title and intellectual property in the database remained with the owner. As the service involved no human intervention or managerial, technical or consultancy support, the receipts did not satisfy the treaty definition of royalty or fees for technical services. In the absence of a permanent establishment, the receipts were not taxable in India as business profits. en-us Fri, 28 Jun 2019 00:00:00 +0530 Thu, 20 May 2021 14:55:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=295139 Subscription receipts for access to an online scientific database were characterised as consideration for access to copyrighted material, not for use of or right to use copyright. The arrangement granted only non-exclusive, non-transferable user access to search, browse, view, print and store material for personal use, while title and intellectual property in the database remained with the owner. As the service involved no human intervention or managerial, technical or consultancy support, the receipts did not satisfy the treaty definition of royalty or fees for technical services. In the absence of a permanent establishment, the receipts were not taxable in India as business profits. Case-Laws Income Tax Fri, 28 Jun 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=295139