Treaty Characterization of Software Income: The Indian Supreme Court’s Landmark Decision of 2 March 2021

Journal
Mehta, A. (Amar)
India; OECD
Bulletin for International Taxation 2021 (Volume 75), No. 4
FormatPDF
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40
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45
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This article considers the recent decision of the Indian Supreme Court (ISC) of 2 March 2021 regarding the characterization of income derived from software under tax treaties (as well as domestic law), together with the implications of the ISC’s judgment.