https://www.taxtmi.com/caselaws?id=799997 Article 12(4) of the India-China Double Taxation Avoidance Agreement covers consideration for managerial, technical or consultancy services provided by a resident of one Contracting State in the other Contracting State. Management and technical services rendered from China to an Indian affiliate, where the Chinese resident has no permanent establishment in India, fall outside that definition. Delivery through email, conference calls and video conferencing does not constitute physical rendition of services in India without a specific treaty or legal provision. Consequently, the fees do not constitute fees for technical services under Article 12(4). en-us Fri, 18 Sep 2026 00:00:00 +0530 Wed, 30 Sep 2026 08:41:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799997 Article 12(4) of the India-China Double Taxation Avoidance Agreement covers consideration for managerial, technical or consultancy services provided by a resident of one Contracting State in the other Contracting State. Management and technical services rendered from China to an Indian affiliate, where the Chinese resident has no permanent establishment in India, fall outside that definition. Delivery through email, conference calls and video conferencing does not constitute physical rendition of services in India without a specific treaty or legal provision. Consequently, the fees do not constitute fees for technical services under Article 12(4). Case-Laws Income Tax Fri, 18 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799997