https://www.taxtmi.com/caselaws?id=767826 Payments made under a shared services arrangement for global brand support, communications, and technology/knowledge management were examined under Article 13(3) of the India-UK DTAA. The payments were found not to involve transfer of copyright, intellectual property, or any right to commercially exploit work or equipment, and mere access to software, systems, guidance, or support services was treated as insufficient to constitute royalty. As the amounts were not for use of, or the right to use, copyright or for treaty-defined technical experience, they fell outside Article 13(3). No withholding tax obligation arose under section 195. en-us Tue, 18 Feb 2025 00:00:00 +0530 Wed, 26 Mar 2025 06:50:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767826 Payments made under a shared services arrangement for global brand support, communications, and technology/knowledge management were examined under Article 13(3) of the India-UK DTAA. The payments were found not to involve transfer of copyright, intellectual property, or any right to commercially exploit work or equipment, and mere access to software, systems, guidance, or support services was treated as insufficient to constitute royalty. As the amounts were not for use of, or the right to use, copyright or for treaty-defined technical experience, they fell outside Article 13(3). No withholding tax obligation arose under section 195. Case-Laws Income Tax Tue, 18 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767826