https://www.taxtmi.com/caselaws?id=412784 Arm's length remuneration paid to the Indian affiliate was treated as sufficient compensation for the functions performed, so no further profits were attributable to the alleged dependent agent permanent establishment for those same activities. The software receipts were also held not to be royalty, because royalty arises only where the payer acquires a copyright right and not where software is merely supplied or resold for use without transfer of copyright. The commentary therefore states that transfer pricing at arm's length can exhaust profit attribution for compensated functions, and that software supply receipts do not become royalty absent copyright rights. en-us Wed, 22 Sep 2021 00:00:00 +0530 Mon, 27 Sep 2021 07:56:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=412784 Arm's length remuneration paid to the Indian affiliate was treated as sufficient compensation for the functions performed, so no further profits were attributable to the alleged dependent agent permanent establishment for those same activities. The software receipts were also held not to be royalty, because royalty arises only where the payer acquires a copyright right and not where software is merely supplied or resold for use without transfer of copyright. The commentary therefore states that transfer pricing at arm's length can exhaust profit attribution for compensated functions, and that software supply receipts do not become royalty absent copyright rights. Case-Laws Income Tax Wed, 22 Sep 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=412784