Leadership Training Not Managerial Service Under DTAA; Affects India-Sweden & India-Portugal Taxation Articles.

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....Accrual of income in India - rendering leadership training to employees of SAPL cannot be said as rendering managerial services so as to fall outside the ambit of fees for technical services under Article 12 (3) of the DTAA between India and Sweden read with its Protocol and the resultant Article 12 of India and Portuguese treaty. - AT....