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Treaty between India and Netherlands – Indian advance ruling: payment to a non-resident for consultancy services is not fees for technical service

|Treaty Development|India; Netherlands
India; Netherlands

The Indian Authority for Advance Rulings (AAR) delivered a ruling dated 6 December 2013 in the case of Endemol India Private Limited (AAR No. 1075 of 2011) that payments made to a non-resident for procuring certain consultancy services would not constitute fees for technical services (FTS) under article 12 of the India - Netherlands Income and Capital Tax Treaty (1988) (as amended through 2012) (t…

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