Indian Tribunal Holds MFN Clause Regarding Fees for Technical Service in Tax Treaty with Israel Applies Automatically

The Ahmedabad Income Tax Appellate Tribunal recently issued a decision concerning the application of the MFN clause originally included in the 1996 India-Israel tax treaty in relation to fees for technical services (FTS). The case involved an Indian pharmaceutical company that made payments to a company in Israel for active pharmaceutical ingredient and formulation services. The Indian company …
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