India-UK DTAA | Consideration For Availing Services That Require Technical Expertise Not FTS Unless Recipient Absorbs Technology: Delhi HC
The Delhi High Court has made it clear that consideration paid for merely availing services that require technical expertise would not qualify as ‘Fees for Technical Service’ under Article 13 of the India-UK DTAA. A division bench of Justices Vibhu Bakhru and Tejas Karia observed that unless the recipient absorbs the technology and exploits it…