The Delhi High Court recently published its decision concerning whether the MFN clause included in the final protocol to the 1992 income and capital tax treaty with France may incorporate the more favorable scope of fees for technical services (FTS) under the 1993 income and capital tax treaty with the UK. The case involved Steria (India) Ltd. (Steria India), which entered into a management services agreement in 2009 with French-based Groupe Steria SCA (Steria France). Under the agreement, Steria France provided various management services for which for which Steria India paid management fees. Steria India applied for an advance ruling...