https://www.taxtmi.com/caselaws?id=755067 Under the India-UK DTAA, receipts under a composite contract may be separately characterised as business profits or fees for technical services where the relevant treaty provisions apply; the existence of a service permanent establishment does not determine the character of all contract receipts. Fees for technical services require an actual transfer of technical knowledge, experience, skill, know-how or processes enabling independent application by the recipient; advisory and operational assistance alone do not meet the "make available" threshold. Fees for services used for events conducted outside India to earn foreign-source income fall within the exception for services utilised in an overseas business or source of income. en-us Wed, 03 Jul 2024 00:00:00 +0530 Thu, 04 Jul 2024 14:03:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755067 Under the India-UK DTAA, receipts under a composite contract may be separately characterised as business profits or fees for technical services where the relevant treaty provisions apply; the existence of a service permanent establishment does not determine the character of all contract receipts. Fees for technical services require an actual transfer of technical knowledge, experience, skill, know-how or processes enabling independent application by the recipient; advisory and operational assistance alone do not meet the "make available" threshold. Fees for services used for events conducted outside India to earn foreign-source income fall within the exception for services utilised in an overseas business or source of income. Case-Laws Income Tax Wed, 03 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755067