https://www.taxtmi.com/caselaws?id=802477 Article 13 of the India-UK tax treaty requires technical or consultancy services of the kind in issue to make technical knowledge or skills available for the recipient's independent use; managerial services fall outside the definition of fees for technical services. IT, shared information, group support, regional and other support charges are not taxable as fees for technical services where there is no evidence that the recipient can independently perform the services using transferred knowledge or skills. Charges for centrally procured standard third-party software supplied to group entities at cost also fall outside that category where the arrangement provides no technical, managerial or consultancy services and makes no technical knowledge, expertise or processes available. en-us Fri, 09 Oct 2026 00:00:00 +0530 Fri, 06 Nov 2026 08:29:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=802477 Article 13 of the India-UK tax treaty requires technical or consultancy services of the kind in issue to make technical knowledge or skills available for the recipient's independent use; managerial services fall outside the definition of fees for technical services. IT, shared information, group support, regional and other support charges are not taxable as fees for technical services where there is no evidence that the recipient can independently perform the services using transferred knowledge or skills. Charges for centrally procured standard third-party software supplied to group entities at cost also fall outside that category where the arrangement provides no technical, managerial or consultancy services and makes no technical knowledge, expertise or processes available. Case-Laws Income Tax Fri, 09 Oct 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=802477