https://www.taxtmi.com/caselaws?id=471590 Article 12(4) of the India-Netherlands tax treaty treats consideration for industrial, commercial or scientific experience as royalty only where know-how is transferred so that the recipient can independently use the knowledge, skill or experience. Information technology, operational, marketing, safety, engineering, administrative and legal support involved service performance and did not make available know-how to the Indian entity. Cost allocations without markup represented reimbursement of expenditure rather than royalty consideration. Management and business support service fees therefore fell outside the treaty definition of royalty, and the related addition was deleted. en-us Tue, 08 Apr 2025 00:00:00 +0530 Wed, 09 Sep 2026 19:00:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471590 Article 12(4) of the India-Netherlands tax treaty treats consideration for industrial, commercial or scientific experience as royalty only where know-how is transferred so that the recipient can independently use the knowledge, skill or experience. Information technology, operational, marketing, safety, engineering, administrative and legal support involved service performance and did not make available know-how to the Indian entity. Cost allocations without markup represented reimbursement of expenditure rather than royalty consideration. Management and business support service fees therefore fell outside the treaty definition of royalty, and the related addition was deleted. Case-Laws Income Tax Tue, 08 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471590