https://www.taxtmi.com/caselaws?id=471844 Payments for Global Brand, Global Communications, and Global Technology/Knowledge Management services under a shared-services arrangement do not constitute royalty under Article 13(3) of the India-UK tax treaty where they confer no right to use or commercially exploit trademarks, copyrights, confidential know-how, or other intellectual property. Internal access to third-party software, databases and technology tools remains use of a copyrighted article where reproduction, sublicensing, transfer and commercial-exploitation rights are absent. Routine strategy, training, coordination, advisory and communication support does not impart specialised proprietary commercial experience. The payments are therefore not chargeable to tax in India, and no withholding obligation arises under section 195. en-us Wed, 17 Dec 2025 00:00:00 +0530 Sat, 19 Sep 2026 14:01:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471844 Payments for Global Brand, Global Communications, and Global Technology/Knowledge Management services under a shared-services arrangement do not constitute royalty under Article 13(3) of the India-UK tax treaty where they confer no right to use or commercially exploit trademarks, copyrights, confidential know-how, or other intellectual property. Internal access to third-party software, databases and technology tools remains use of a copyrighted article where reproduction, sublicensing, transfer and commercial-exploitation rights are absent. Routine strategy, training, coordination, advisory and communication support does not impart specialised proprietary commercial experience. The payments are therefore not chargeable to tax in India, and no withholding obligation arises under section 195. Case-Laws Income Tax Wed, 17 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471844