https://www.taxtmi.com/caselaws?id=461259 Payments under a shared services arrangement for global brand, communications, and technology/knowledge management were not royalty under Article 13(3) of the India-UK DTAA because the services were internal support functions, advisory in nature, and confined to member firms' use. No copyright, intellectual property, or right to use industrial, commercial, or scientific equipment was transferred, and the payments did not constitute consideration for information concerning industrial, commercial, or scientific experience. As the amounts fell outside the treaty definition of royalty, no tax was deductible at source under section 195. The mutuality and reimbursement arguments were not examined further once non-taxability as royalty was found. en-us Fri, 17 Jan 2025 00:00:00 +0530 Mon, 24 Mar 2025 21:44:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=461259 Payments under a shared services arrangement for global brand, communications, and technology/knowledge management were not royalty under Article 13(3) of the India-UK DTAA because the services were internal support functions, advisory in nature, and confined to member firms' use. No copyright, intellectual property, or right to use industrial, commercial, or scientific equipment was transferred, and the payments did not constitute consideration for information concerning industrial, commercial, or scientific experience. As the amounts fell outside the treaty definition of royalty, no tax was deductible at source under section 195. The mutuality and reimbursement arguments were not examined further once non-taxability as royalty was found. Case-Laws Income Tax Fri, 17 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=461259