The Kolkata Income Tax Appellate Tribunal has recently issued a ruling on whether management support services are considered fees for technical services (FTS) under the 2010 Finland-India tax treaty. The case involved Finnish-based Outotec OYJ, a metal and mineral processing technologies company, and its group company, Outotec India Pvt Ltd. In the 2009-10 tax year, Outotec OYJ received payments for management support and related services provided to Outotec India amounting to approximately INR 8.2 million. Outotec OYJ took the position that the payments were outside the scope of FTS, and were therefore not taxable in India. Based on this position,...