https://www.taxtmi.com/highlights?id=105007 Automated airline reservation and operational software subscription services, delivered through overseas-hosted software without human intervention as a standard facility, are not treated as fees for technical services under the India-Netherlands DTAA. Technical services, when distinguished from mere use of a standard facility, require human interface or application of the human mind. Training and support for use of the systems do not satisfy the treaty's make available requirement where customers cannot independently apply the underlying technology and the provider retains the relevant intellectual-property rights. The consideration is therefore not taxable as fees for technical services under the treaty or the Act. en-us Thu, 15 Oct 2026 05:44:05 +0530 Thu, 15 Oct 2026 05:44:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=105007 Automated airline reservation and operational software subscription services, delivered through overseas-hosted software without human intervention as a standard facility, are not treated as fees for technical services under the India-Netherlands DTAA. Technical services, when distinguished from mere use of a standard facility, require human interface or application of the human mind. Training and support for use of the systems do not satisfy the treaty's make available requirement where customers cannot independently apply the underlying technology and the provider retains the relevant intellectual-property rights. The consideration is therefore not taxable as fees for technical services under the treaty or the Act. Highlights Income Tax Thu, 15 Oct 2026 05:44:05 +0530 https://www.taxtmi.com/highlights?id=105007