https://www.taxtmi.com/caselaws?id=471443 Article 13 of the India-UK Tax Treaty taxes fees for technical services only where technical or consultancy services satisfy the treaty conditions, including making available technical knowledge, experience, skill, know-how or processes, or developing and transferring a technical plan or design. Recurring group management support for business and commercial functions does not meet that standard where it neither constitutes qualifying technical or consultancy services nor enables the Indian recipient to independently apply technical knowledge or skill without further recourse to the provider. The consideration is therefore not taxable in India as fees for technical services under Article 13. en-us Thu, 24 Oct 2024 00:00:00 +0530 Wed, 02 Sep 2026 19:01:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471443 Article 13 of the India-UK Tax Treaty taxes fees for technical services only where technical or consultancy services satisfy the treaty conditions, including making available technical knowledge, experience, skill, know-how or processes, or developing and transferring a technical plan or design. Recurring group management support for business and commercial functions does not meet that standard where it neither constitutes qualifying technical or consultancy services nor enables the Indian recipient to independently apply technical knowledge or skill without further recourse to the provider. The consideration is therefore not taxable in India as fees for technical services under Article 13. Case-Laws Income Tax Thu, 24 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471443