India-Finland Tax Treaty: Software sales and support services not classified as 'royalty', impacting taxability.

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Full Text of the Document

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....Taxability of receipt from sale of 'off-the shelf' software as 'Royalty' - India-Finland Tax Treaty - amount received by the assessee from its distributor for sale of specialized software and maintenance and support services (including upgrades) cannot be held as being in the nature of ‘royalty’....