A collection of the brief insights throughout April 2024 of the type provided on an ad hoc basis in our Latest digital tax byte update.
30 April 2024 - Reimbursement by Indian associate of cross charge for third-party group software licence not a ‘royalty’
In a recent ruling, the Delhi bench of the Income-tax Appellate Tribunal concluded that the reimbursement amount received by a non-resident taxpayer towards the cross charge of a cost of third-party software procured centrally under a global agreement for all the entities within the group cannot be characterised as a royalty under the India-Denmark double tax treaty in the absence of any transfer of copyright in the software. The ruling reaffirms the view laid down by the Supreme Court regarding taxability of software licence fees.
Read more in this PwC alert.
29 April 2024 - Jurisdictions criticise UN Tax Committee proposal to widen source taxation on services
