ITAT Rules Rothschild’s Intra-Group Advisory and Support Services Not Taxable as FTS Under India-UK DTAA

The ITAT rules that intra-group advisory and support services are not taxable as Fees for Technical Services under Article 13(4) of the India-UK DTAA

By Nandan GK - On April 24, 2025 8:28 pm - 2 mins read

ITAT - ITAT Rules - Rothschild’s Intra-Group Advisory - Support Services - taxscan

In a recent ruling, the Income Tax Appellate Tribunal (ITAT) Delhi bench held that intra-group and advisory support services provided are not taxable as Fees for Technical Services (FTS) under the India-UK Double Taxation Avoidance Agreement (DTAA), as they do not meet the ‘make available’ criterion. The assessee, N.M. Rothschild & Sons Ltd., is a…

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