India-UK Tax Treaty: Technical Services Fees Not Taxable if Designs Aren't Reusable by Indian Entities under Article 13(4)(c.

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....Taxability of Fees for technical services (FTS) - In Article–13(4)(c) of the India–UK tax treaty the words “or consists of the development and transfer of a technical plan or technical design”, appearing in the second limb has to be read in conjunction with “make available technical knowledge, experience, skill, knowhow or processes” - since technical design/drawings/plans supplied by the assessee cannot be used by the Indian entity in any other project in future same is not FTS taxable in India....