The Resource Case note : payments to foreign entity to accelerate access to online content not income under Income Tax Act or United States Treaty

Case note : payments to foreign entity to accelerate access to online content not income under Income Tax Act or United States Treaty

Label
Case note : payments to foreign entity to accelerate access to online content not income under Income Tax Act or United States Treaty
Title
Case note : payments to foreign entity to accelerate access to online content not income under Income Tax Act or United States Treaty
Creator
Subject
Language
eng
Summary
This case note summarizes the recent ruling by the Authority for Advance Rulings in Akamai Technologies Inc. that payments received by a foreign company from its Indian subsidiary for a content delivery solution to accelerate online content and business processes under a services reseller agreement were not in the nature of fees for technical services or royalties under the Income-tax Act, 1961 or the India-United States Income Tax Treaty (1989), and that the arrangement did not create a permanent establishment of the foreign company in India
Citation source
In: Asia-Pacific tax bulletin. - Amsterdam. - Vol. 24 (2018), no. 5 ; 3 p
http://library.link/vocab/creatorName
  • Dugar, A
  • Bhandari, L
Geographic coverage
Asia
Language note
English
http://library.link/vocab/subjectName
  • case law
  • advance ruling
  • income classification
  • technical services
  • royalties
  • PE
  • tax treaty
Label
Case note : payments to foreign entity to accelerate access to online content not income under Income Tax Act or United States Treaty
Instantiates
Publication
Label
Case note : payments to foreign entity to accelerate access to online content not income under Income Tax Act or United States Treaty
Publication

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