Tax alert: Design services taxable as FTS under India-Singapore tax treaty  

3 November 2023

The Delhi Bench of the Income-tax Appellate Tribunal, based on the facts of the case, has held that the taxpayer was making available to the Indian company (A Co) all deliverables for the use of A Co. This enabled A Co to apply all the deliverables for its business purposes. Thus, the conditions of Article 12(4)(b) and (c) of the India-Singapore tax treaty, were satisfied and the consideration was taxable as fees for technical services.

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