https://www.taxtmi.com/caselaws?id=470552 Borrowed service charges received from an Indian group entity are examined under the India-Singapore tax treaty's provisions on fees for technical or included services, royalty and business profits. Article 12(4)(b) requires technical knowledge, experience, skill, know-how or processes to be made available so that the recipient can apply the technology. As the services did not make technical knowledge or skill available to the Indian entity, the charges are not fees for technical or included services or royalty. They are characterised as business income under Article 7, consistently with earlier decisions and an accepted mutual-agreement resolution where the services remained unchanged. en-us Tue, 08 Oct 2024 00:00:00 +0530 Fri, 31 Jul 2026 08:27:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470552 Borrowed service charges received from an Indian group entity are examined under the India-Singapore tax treaty's provisions on fees for technical or included services, royalty and business profits. Article 12(4)(b) requires technical knowledge, experience, skill, know-how or processes to be made available so that the recipient can apply the technology. As the services did not make technical knowledge or skill available to the Indian entity, the charges are not fees for technical or included services or royalty. They are characterised as business income under Article 7, consistently with earlier decisions and an accepted mutual-agreement resolution where the services remained unchanged. Case-Laws Income Tax Tue, 08 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470552