https://www.taxtmi.com/caselaws?id=767777 Payments made under a shared services arrangement for global brand, communications, technology and knowledge-management support were examined against Article 13(3) of the India-UK DTAA. The Tribunal held that internal support, guidance, common standards and knowledge-sharing, without transfer of copyright, intellectual property, or any right to exploit such rights, did not constitute royalty. It followed its earlier view in the assessee's own and connected matters and rejected the argument that the character of the payments changed because the services related to brand or technology support. The payments were therefore outside the treaty definition of royalty and no tax deduction at source was required under section 195. en-us Fri, 21 Mar 2025 00:00:00 +0530 Mon, 24 Mar 2025 10:53:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767777 Payments made under a shared services arrangement for global brand, communications, technology and knowledge-management support were examined against Article 13(3) of the India-UK DTAA. The Tribunal held that internal support, guidance, common standards and knowledge-sharing, without transfer of copyright, intellectual property, or any right to exploit such rights, did not constitute royalty. It followed its earlier view in the assessee's own and connected matters and rejected the argument that the character of the payments changed because the services related to brand or technology support. The payments were therefore outside the treaty definition of royalty and no tax deduction at source was required under section 195. Case-Laws Income Tax Fri, 21 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767777