Case Law Analysis
|Income Tax Appellate Tribunal
DTAA Article 12 | Credit Rating Fees Not Royalty or FTS Without Transfer of Technical Know-How : ITAT Delhi
The ITAT Delhi has ruled that fees paid for credit ratings and surveillance services do not qualify as royalty or fees for technical services under the India-Singapore DTAA unless there is a transfer of technical know-how to the client. This sets a crucial precedent for multinational rating agencies and foreign service providers, clarifying the taxability of intangible services in cross-border transactions.