https://www.taxtmi.com/caselaws?id=444542 Receipts from distribution of online database products were treated as not taxable as royalty because access to the database did not transfer copyright, any right to reproduce or exploit the content, or any right to use industrial, commercial or scientific experience under the treaty. The same arrangement was also held insufficient to establish an agency permanent establishment in India, as the distributor relationship and contractual terms alone did not prove the requisite nexus or authority. On both grounds, the receipts were held outside Indian taxability under the India-UK DTAA. en-us Tue, 09 May 2023 00:00:00 +0530 Wed, 18 Oct 2023 06:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=444542 Receipts from distribution of online database products were treated as not taxable as royalty because access to the database did not transfer copyright, any right to reproduce or exploit the content, or any right to use industrial, commercial or scientific experience under the treaty. The same arrangement was also held insufficient to establish an agency permanent establishment in India, as the distributor relationship and contractual terms alone did not prove the requisite nexus or authority. On both grounds, the receipts were held outside Indian taxability under the India-UK DTAA. Case-Laws Income Tax Tue, 09 May 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=444542