https://www.taxtmi.com/highlights?id=105887 The India-UK DTAA's make available test requires the recipient to acquire technical knowledge or know-how that can be used independently, without further assistance from the service provider. IT and shared information service charges do not qualify as fees for technical services where the recipient acquires no such capability. Charges for standard third-party software procured for group affiliates on a cost-to-cost basis also fall outside fees for technical services where the test is not met. Managerial services are excluded from fees for technical services under Article 13(4), including managerial group support services. en-us Fri, 06 Nov 2026 10:54:05 +0530 Fri, 06 Nov 2026 10:54:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=105887 The India-UK DTAA's make available test requires the recipient to acquire technical knowledge or know-how that can be used independently, without further assistance from the service provider. IT and shared information service charges do not qualify as fees for technical services where the recipient acquires no such capability. Charges for standard third-party software procured for group affiliates on a cost-to-cost basis also fall outside fees for technical services where the test is not met. Managerial services are excluded from fees for technical services under Article 13(4), including managerial group support services. Highlights Income Tax Fri, 06 Nov 2026 10:54:05 +0530 https://www.taxtmi.com/highlights?id=105887