Payments for global telecommunication facility not “fees for technical services”
The Supreme Court of India held that payments received by a Danish shipping company for its global telecommunication system (payments from Indian agents) were reimbursements in nature. Because no profit element was embedded in these payments and also because the foreign company had not provided any technical services to the Indian agents, the payments were not taxable as fees for technical services. Read a March 2017 report [PDF 333 KB] of KPMG