The Indian Authority for Advance Ruling (AAR) delivered a ruling dated 26 October 2005 in the case of ABC Ltd & XYZ Ltd (Note: The taxpayer(s) details have not been released) on whether payments made to a foreign company for Business Information Reports (BIRs) are taxable in India under the India-United Kingdom tax treaty (the tax treaty). (a) Facts. The Applicant (i.e. a UK company) was a subsidiary of A Ltd. B Ltd was a 100% subsidiary of C Ltd, a company incorporated in Cayman Islands. A Ltd held 10% of the shares of C Ltd, while the remaining 90%...