https://www.taxtmi.com/caselaws?id=413391 Management support services comprising operational, accounting, legal, purchasing, personnel, training and IT support were treated as largely advisory and repetitive, but they fell outside fee for technical services because they did not satisfy the treaty's 'make available' test. The record showed no transfer of technical knowledge, skill, know-how or processes enabling the Indian recipient to apply the services independently in future, and the continuing need for assistance indicated no such capability had been imparted. Accordingly, the services were not taxable as fee for technical services under Article 12(4)(b) of the India-Singapore DTAA. en-us Fri, 24 Sep 2021 00:00:00 +0530 Mon, 11 Oct 2021 08:27:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=413391 Management support services comprising operational, accounting, legal, purchasing, personnel, training and IT support were treated as largely advisory and repetitive, but they fell outside fee for technical services because they did not satisfy the treaty's 'make available' test. The record showed no transfer of technical knowledge, skill, know-how or processes enabling the Indian recipient to apply the services independently in future, and the continuing need for assistance indicated no such capability had been imparted. Accordingly, the services were not taxable as fee for technical services under Article 12(4)(b) of the India-Singapore DTAA. Case-Laws Income Tax Fri, 24 Sep 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=413391