India Rules that UK-India Treaty Definition of FTS Cannot be Imported Despite Protocol to India-France Tax Treaty

India's Authority for Advance Rulings recently provided a ruling on the application of the protocol to the tax treaty between India and France to import the definition of fees for technical services (FTS) from the tax treaty between India and the United Kingdom. The protocol includes the provision that if India signs any convention, agreement or protocol after 1 September 1989 with a third part…
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