OrbitaxTreaty between India and Germany – Indian decision that Royalty / Fees for Technical Services should be taxed on receipt basis irrespective of the method of accounting followed
|Treaty Development|India; Germany
The Indian High Court issued its decision on 22 October 2012 in the case of DIT v. Siemens Aktiengesellschaft (ITA No. 124 of 2010) that the royalty / fees for technical services (FTS) would be taxable in the year in which the income is received. The High Court did not accept the contention of the tax authorities that the royalty or FTS should be taxed when the income is recorded in…
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