India-Finland Tax Treaty: Payments for Specialized Software Sales and Services Not Classified as "Royalty" Under Article 12.

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Full Text of the Document

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....Income accrued in India - Amount received by the assessee from its distributors for sale of specialized software and maintenance and support services (including upgrades) cannot be held as being in the nature of “royalty” as per Article 12 of the India-Finland tax treaty. - AT....