https://www.taxtmi.com/highlights?id=74106 Accrual of income in India - PE in India or not? - use or right to use brand name/trade mark - the receipts cannot be treated as royalty under Article 12(3)(a) of the Tax Treaty. Similarly, the fee received cannot be treated as royalty under Article 12(3)(b) as there is no transfer of use or right to use any industrial or commercial or scientific equipments. In any case of the matter, the fees received are purely for certain services, therefore, in our view, they cannot be treated as royalty. - AT en-us Thu, 11 Jan 2024 18:27:24 +0530 Thu, 11 Jan 2024 18:27:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=74106 Accrual of income in India - PE in India or not? - use or right to use brand name/trade mark - the receipts cannot be treated as royalty under Article 12(3)(a) of the Tax Treaty. Similarly, the fee received cannot be treated as royalty under Article 12(3)(b) as there is no transfer of use or right to use any industrial or commercial or scientific equipments. In any case of the matter, the fees received are purely for certain services, therefore, in our view, they cannot be treated as royalty. - AT Highlights Income Tax Thu, 11 Jan 2024 18:27:24 +0530 https://www.taxtmi.com/highlights?id=74106