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Income Tax - Highlights / Catch Notes

Home Highlights April 2019 Year 2019 This

Taxability of Fees for technical services (FTS) - In ...

Income Tax

April 10, 2019

Taxability of Fees for technical services (FTS) - In Article–13(4)(c) of the India–UK tax treaty the words “or consists of the development and transfer of a technical plan or technical design”, appearing in the second limb has to be read in conjunction with “make available technical knowledge, experience, skill, knowhow or processes” - since technical design/drawings/plans supplied by the assessee cannot be used by the Indian entity in any other project in future same is not FTS taxable in India

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