Indian-UK Tax Treaty: Subscription Revenue Classified as Royalty, Article 13(6) Inapplicable, Impact on Permanent Establishment in India.

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Full Text of the Document

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....Characterizing subscription revenue received - Indian–United Kingdom Tax Treaty - PE in India - not only the subscription fee is in the nature of royalty but the provision of Article–13(6) of the Tax Treaty would not be applicable to the assessee....