Topic

India-Singapore DTAA

2 articlesLatest July 2026
India-Singapore DTAA | 'Make Available' Condition Mandatory for FTS Taxability Under Article 12(4)(b) : ITAT Mumbai
Case Law Analysis
|Income Tax Appellate Tribunal

India-Singapore DTAA | 'Make Available' Condition Mandatory for FTS Taxability Under Article 12(4)(b) : ITAT Mumbai

ITAT Mumbai holds that management support services do not qualify as Fees for Technical Services (FTS) under the India-Singapore DTAA unless the 'make available' condition is satisfied, clarifying the taxability of cross-border service fees for multinational enterprises. The ruling reinforces the need for technical knowledge transfer to trigger FTS taxation under tax treaties.

Section 9(1)(vii) & India-Singapore DTAA | Project-Specific Design Services Not Taxable as Fees for Technical Services : ITAT Mumbai
Case Law Analysis
|Income Tax Appellate Tribunal

Section 9(1)(vii) & India-Singapore DTAA | Project-Specific Design Services Not Taxable as Fees for Technical Services : ITAT Mumbai

ITAT Mumbai rules that payments for project-specific architectural and structural design services to Singapore entities do not qualify as Fees for Technical Services under the India-Singapore DTAA, exempting them from TDS under Section 195. The ruling clarifies the scope of FTS, preventing disallowance under Section 40(a)(i) for real estate developers and similar businesses.

Continue exploring