IT Support Services Not Classified as Fees for Technical Services Under DTAA with Belgium Due to Lack of Knowledge Transfer.

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....IT support Services - DTAA with Belgium - payment of consideration would be regarded as FTS only if the twin test of rendering services and making technical knowledge available is satisfied - IT support services is in the nature of routine services and no manner has given any benefit of technical knowledge, skill or expertise to apply it in future to perform the functions independently - Not a FTS....