https://www.taxtmi.com/caselaws?id=754202 Under the cited treaty framework, payments for clinical trials, bio-equivalence studies and consultancy were treated as fees for technical services only where technical knowledge, skill or know-how was made available to the recipient; mere performance of services did not satisfy that test, and business profits from the Thailand payments were not taxable absent a permanent establishment. Online access to databases, publications and journals was characterised as access to copyrighted content, not use of copyright, so the subscription payments were not royalty. A principal-to-principal purchase of software was likewise treated as acquisition of a product, not a licence of copyright, and the market survey and development reimbursement for work performed and used outside India was not taxable in India. en-us Fri, 17 May 2024 00:00:00 +0530 Tue, 18 Jun 2024 15:09:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=754202 Under the cited treaty framework, payments for clinical trials, bio-equivalence studies and consultancy were treated as fees for technical services only where technical knowledge, skill or know-how was made available to the recipient; mere performance of services did not satisfy that test, and business profits from the Thailand payments were not taxable absent a permanent establishment. Online access to databases, publications and journals was characterised as access to copyrighted content, not use of copyright, so the subscription payments were not royalty. A principal-to-principal purchase of software was likewise treated as acquisition of a product, not a licence of copyright, and the market survey and development reimbursement for work performed and used outside India was not taxable in India. Case-Laws Income Tax Fri, 17 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=754202