https://www.taxtmi.com/caselaws?id=33855 Technical supervision fees under a consultancy agreement were treated as consideration for management-related services rather than exempt industrial or commercial profits under Article III of the India-Sweden DTAA. Although Article III(1) exempts industrial or commercial profits of a foreign enterprise absent a permanent establishment, Article III(3) excludes management charges from that expression. Because the agreement required supervision of installation, testing, and commissioning in addition to consultancy, the consideration for those supervisory activities fell within the treaty exclusion. The fees were therefore outside the Article III exemption and taxable. en-us Fri, 12 Jun 2009 00:00:00 +0530 Wed, 07 Sep 2011 17:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=33855 Technical supervision fees under a consultancy agreement were treated as consideration for management-related services rather than exempt industrial or commercial profits under Article III of the India-Sweden DTAA. Although Article III(1) exempts industrial or commercial profits of a foreign enterprise absent a permanent establishment, Article III(3) excludes management charges from that expression. Because the agreement required supervision of installation, testing, and commissioning in addition to consultancy, the consideration for those supervisory activities fell within the treaty exclusion. The fees were therefore outside the Article III exemption and taxable. Case-Laws Income Tax Fri, 12 Jun 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=33855