https://www.taxtmi.com/caselaws?id=461248 Payments under a shared services arrangement for global brand support, communications, and technology/knowledge management were not royalty under Article 13(3) of the India-UK DTAA because they involved internal-use services rather than any transfer of copyright, trademark, patent, equipment, or proprietary intellectual property. The arrangement also did not amount to imparting industrial, commercial, or scientific experience. Applying the later judicial position that royalty requires a transfer of copyright or a right to exploit it, the amounts fell outside the royalty definition and no tax deduction at source was required under Section 195. en-us Wed, 27 Jul 2022 00:00:00 +0530 Mon, 24 Mar 2025 19:42:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=461248 Payments under a shared services arrangement for global brand support, communications, and technology/knowledge management were not royalty under Article 13(3) of the India-UK DTAA because they involved internal-use services rather than any transfer of copyright, trademark, patent, equipment, or proprietary intellectual property. The arrangement also did not amount to imparting industrial, commercial, or scientific experience. Applying the later judicial position that royalty requires a transfer of copyright or a right to exploit it, the amounts fell outside the royalty definition and no tax deduction at source was required under Section 195. Case-Laws Income Tax Wed, 27 Jul 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=461248