https://www.taxtmi.com/caselaws?id=456496 Under the India-UK tax treaty, fees for technical services are taxable only when technical or consultancy services make available technical knowledge, experience, skill, know-how or processes to the recipient; mere specialised service delivery is insufficient, and managerial services fall outside that definition. On the facts stated, only some identified services in the bundled Global Management Service Agreement met the make-available test, while others did not or were not clearly classifiable on the incomplete record. Accordingly, the service fee was not wholly taxable as fees for technical services, and no blanket conclusion could be given that tax was not deductible at source on the entire fee. en-us Fri, 07 Nov 2008 00:00:00 +0530 Thu, 28 May 2026 11:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=456496 Under the India-UK tax treaty, fees for technical services are taxable only when technical or consultancy services make available technical knowledge, experience, skill, know-how or processes to the recipient; mere specialised service delivery is insufficient, and managerial services fall outside that definition. On the facts stated, only some identified services in the bundled Global Management Service Agreement met the make-available test, while others did not or were not clearly classifiable on the incomplete record. Accordingly, the service fee was not wholly taxable as fees for technical services, and no blanket conclusion could be given that tax was not deductible at source on the entire fee. Case-Laws Income Tax Fri, 07 Nov 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=456496