https://www.taxtmi.com/article/detailed?id=16542 Cross-border telecommunication payments are analysed under the royalty, FTS, and business profits framework in light of a retrospective domestic amendment expanding the meaning of "process" in section 9(1)(vi). The article contrasts static and ambulatory treaty interpretation under article 3(2), noting that domestic amendments cannot unilaterally override pre-existing DTAA terms. It explains that, on the facts discussed, bandwidth and voice termination receipts fall outside royalty and FTS characterisation and are treated as business profits where no permanent establishment exists. en-us Mon, 01 Jun 2026 08:26:51 +0530 Mon, 01 Jun 2026 08:26:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/article/detailed?id=16542 Cross-border telecommunication payments are analysed under the royalty, FTS, and business profits framework in light of a retrospective domestic amendment expanding the meaning of "process" in section 9(1)(vi). The article contrasts static and ambulatory treaty interpretation under article 3(2), noting that domestic amendments cannot unilaterally override pre-existing DTAA terms. It explains that, on the facts discussed, bandwidth and voice termination receipts fall outside royalty and FTS characterisation and are treated as business profits where no permanent establishment exists. Articles Income Tax Mon, 01 Jun 2026 08:26:51 +0530 https://www.taxtmi.com/article/detailed?id=16542