https://www.taxtmi.com/caselaws?id=797952 Live broadcasting licence fees were treated as outside royalty taxation under Article 13(3) of the India-UK tax treaty because a one-time live match feed neither confers an enduring benefit nor constitutes a scientific work or copyrighted work. The contractually agreed 95:5 allocation between live and non-live broadcasting rights remained undisturbed, absent material showing it was unjustified; consideration for non-live rights had already been offered to tax. Release fees paid to permit English players' participation in the IPL were also outside Article 18(2), as they were paid for consent and did not arise from the players' personal activities. en-us Fri, 21 Aug 2026 00:00:00 +0530 Mon, 31 Aug 2026 08:28:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797952 Live broadcasting licence fees were treated as outside royalty taxation under Article 13(3) of the India-UK tax treaty because a one-time live match feed neither confers an enduring benefit nor constitutes a scientific work or copyrighted work. The contractually agreed 95:5 allocation between live and non-live broadcasting rights remained undisturbed, absent material showing it was unjustified; consideration for non-live rights had already been offered to tax. Release fees paid to permit English players' participation in the IPL were also outside Article 18(2), as they were paid for consent and did not arise from the players' personal activities. Case-Laws Income Tax Fri, 21 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797952