https://www.taxtmi.com/highlights?id=103379 Treaty limitations on royalty taxation and the make-available condition restrict taxation of cross-border receipts despite transfer-pricing adjustments. Notional interest requires an invoice-wise factual basis and interest paid, credited, acknowledged as payable or made available; arm's-length recomputation cannot independently create interest taxable under the treaty. Standardised software supplied with restricted end-user rights, connectivity services without rights in equipment or processes, and lease rentals paid by a non-resident outside the treaty source rule do not constitute taxable royalty income. Testing, administrative reimbursements and non-technical managerial training are not fees for included services where they do not transm..... en-us Thu, 03 Sep 2026 08:20:52 +0530 Thu, 03 Sep 2026 08:20:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=103379 Treaty limitations on royalty taxation and the make-available condition restrict taxation of cross-border receipts despite transfer-pricing adjustments. Notional interest requires an invoice-wise factual basis and interest paid, credited, acknowledged as payable or made available; arm's-length recomputation cannot independently create interest taxable under the treaty. Standardised software supplied with restricted end-user rights, connectivity services without rights in equipment or processes, and lease rentals paid by a non-resident outside the treaty source rule do not constitute taxable royalty income. Testing, administrative reimbursements and non-technical managerial training are not fees for included services where they do not transm..... Highlights Income Tax Thu, 03 Sep 2026 08:20:52 +0530 https://www.taxtmi.com/highlights?id=103379