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India Supreme Court Holds Payments for Computer System Use Not Taxable FTS under Tax Treaty with Denmark

|Treaty Development|India-Denmark
India-Denmark

A decision of the Indian Supreme Court was recently published on whether payments for the use of a central computer system qualifies as taxable fees for technical services (FTS) under the 1989 tax treaty with Denmark. The case involved Denmark-based A.P. Moeller-Maersk A/S (Maersk) and the use of its communication system by Indian agents.

As part of its Indian business, Maersk has four Indian…

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