Payments Under DTAA Not FTS if "Make Available" Clause Exists; Classified as Business Income Under Article 7 Instead.

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Full Text of the Document

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....Wherever under the DTAA’s. Make available clause is found, then as there is no imparting, the payment in question is not ‘FTS’ under the Treaty and when there is no ‘FTS’ clause in the treaties, the payment falls under Article 7 of the Treaty and is business income. - AT....