https://www.taxtmi.com/caselaws?id=795836 Under the India-Netherlands Treaty, executive search fees under a distinct agreement were not fees for technical services or royalty because they were neither ancillary to licensed rights nor made available technical knowledge, experience, skill, know-how or processes; the related addition was deleted. Actual-cost reimbursement charges supported by third-party invoices, with no markup or profit element, were likewise not fees for technical services, and the addition was deleted. Management fees require fresh examination of the Shared Services Agreement and each service's nature because managerial services fall outside Article 12(5). Interest on income-tax refunds must be taxed at the Treaty rate under Article 11(2). en-us Fri, 24 Jul 2026 00:00:00 +0530 Tue, 28 Jul 2026 08:30:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795836 Under the India-Netherlands Treaty, executive search fees under a distinct agreement were not fees for technical services or royalty because they were neither ancillary to licensed rights nor made available technical knowledge, experience, skill, know-how or processes; the related addition was deleted. Actual-cost reimbursement charges supported by third-party invoices, with no markup or profit element, were likewise not fees for technical services, and the addition was deleted. Management fees require fresh examination of the Shared Services Agreement and each service's nature because managerial services fall outside Article 12(5). Interest on income-tax refunds must be taxed at the Treaty rate under Article 11(2). Case-Laws Income Tax Fri, 24 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795836