Tribunal Rules Centralized Marketing Services Not a Fee for Technical Services Under DTAA, Excludes Royalty Link.

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....Income taxable in India - payments received from its India customers on account of Centralized Services - Fee for Technical Services - Fee for included services - The Tribunal, after examining the agreements and services provided, concluded that the services were related to publicity, marketing, and advertisement, not technical or consultancy services. Therefore, they did not fall under the definition of FIS as per Article 12(4)(a) or (b) of the DTAA. - The Tribunal reaffirmed that the services provided were not ancillary or subsidiary to the application or enjoyment of any right, property, or information for which a royalty payment was made, thus not qualifying as FIS under Article 12(4)(a).....