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Taxsutra – Indian Tax Tribunal holds Receipts under R&D Cooperation Agreement as Reimbursement, not Royalty; Rejects TaxabilityDec-03-2018

The Indian Income Tax Appellate Tribunal recently ruled that amounts received by the taxpayer, Koninklijke Philips Electronics NV (resident of the Netherlands), from its Indian affiliate under a research and development (R&D) cooperation agreement and master support service agreement were not taxable as royalty or fees for technical services (FTS).