https://www.taxtmi.com/highlights?id=102136 Under the India-Netherlands DTAA, executive search services that are separate from a licensing arrangement and do not make available technical knowledge, skill, know-how or processes are addressed as neither fees for technical services nor royalty. The note also distinguishes managerial services from treaty-defined technical services, while requiring examination of the specific services under a shared-services agreement. Reimbursements of actual expenses without a profit element are treated separately from fees for technical services. Interest on income-tax refunds is subject to the treaty interest provision, and tax on treaty-covered income cannot exceed the treaty-prescribed rate, including through surcharge and cess. Tax deducted at source credit remains subject to factual verification. en-us Tue, 28 Jul 2026 09:36:24 +0530 Tue, 28 Jul 2026 09:36:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=102136 Under the India-Netherlands DTAA, executive search services that are separate from a licensing arrangement and do not make available technical knowledge, skill, know-how or processes are addressed as neither fees for technical services nor royalty. The note also distinguishes managerial services from treaty-defined technical services, while requiring examination of the specific services under a shared-services agreement. Reimbursements of actual expenses without a profit element are treated separately from fees for technical services. Interest on income-tax refunds is subject to the treaty interest provision, and tax on treaty-covered income cannot exceed the treaty-prescribed rate, including through surcharge and cess. Tax deducted at source credit remains subject to factual verification. Highlights Income Tax Tue, 28 Jul 2026 09:36:24 +0530 https://www.taxtmi.com/highlights?id=102136