https://www.taxtmi.com/caselaws?id=307058 Managerial support services rendered on a centralized, non-exclusive basis were treated as managerial in nature and not as Fees for Included Services under Article 12(4)(b) of the India-USA DTAA, because they did not make technical knowledge, skill, know-how, or processes available to the recipient. Subscription to published reports was characterised as access to copyrighted material, not a transfer of copyright, and therefore not royalty under Article 12(3). Customized research advisory was also viewed as advisory service without database access or technology transfer, so it was outside royalty and Fees for Included Services. A limited unresolved quantum was remitted for further adjudication. en-us Mon, 30 May 2022 00:00:00 +0530 Tue, 18 Apr 2023 11:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=307058 Managerial support services rendered on a centralized, non-exclusive basis were treated as managerial in nature and not as Fees for Included Services under Article 12(4)(b) of the India-USA DTAA, because they did not make technical knowledge, skill, know-how, or processes available to the recipient. Subscription to published reports was characterised as access to copyrighted material, not a transfer of copyright, and therefore not royalty under Article 12(3). Customized research advisory was also viewed as advisory service without database access or technology transfer, so it was outside royalty and Fees for Included Services. A limited unresolved quantum was remitted for further adjudication. Case-Laws Income Tax Mon, 30 May 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=307058