16 August 2017 Internal T.I. 2017-0701291I7 - Exclusive Distributorship Rights -- attach -- Article 12
lump sum paid for distributorship rights was not a royalty
Article 12
Director of Income Tax v. A.P. Moller Maersk, Civil Appeal No. 2960 of 2017 (Supreme Court Of India, Civil Appellate Jurisdiction) -- attach -- Article 12
computer tracking-system charges of a Danish company to local agents were profits of its international shipping business rather than for technical services
DCIT v. Bombardier Transportation India Pvt. Ltd, ITA No.555/Ahd/2016 (ITAT Ahmedabad) -- attach -- Article 12
not a technical services royalty if Indian services recipient did not acquire know-how
Tech Mahindra Limited v Commissioner of Taxation, [2016] FCAFC 130 -- attach -- Article 12
exception in the Australia-India Treaty for “effectively connected” royalties was not intended to exempt royalties not attributable to the source country PE from source country withholding
Technip Singapore Pte Ltd. v. Director of Income Tax (2016), W.P.(C)-7416/2012 (Delhi High Court) -- attach -- Article 12
charges for use of the installer’s own equipment were not royalties for equipment use
15 June 2015 External T.I. 2014-0525501E5 - Royalty payments & the US or UK Treaties -- attach -- Article 12
fees paid to the U.S. or U.K. for access to customer lists were exempt royalties
23 January 2015 External T.I. 2013-0509771E5 - Oil & gas payments made to U.S. resident -- attach -- Article 12
non-application of Art. 12 of US Treaty to resource royalties
5 January 1993 T.I. 922053 (November 1993 Access Letter, p. 509, ¶C180-153; Tax Window, No. 28, p. 8, ¶2404) -- attach -- Article 12
MNR v. Paris Canada Films Ltd., 62 DTC 1338, [1962] CTC 538 (Ex Ct) -- attach -- Article 12
93 C.R. - Q. 29 -- attach -- Article 12
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