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Quiz · ITAT Ruling Fees for Technical Services DTAA

Two Prelims-style questions on this topic from 29 August 2026. Choose an option to check yourself, then open the full note or today’s full quiz.

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News · ITAT Ruling Fees for Technical Services DTAA

Consider the following statements regarding the taxation of Fees for Technical Services (FTS) under bilateral tax treaties:1.Executive search fees have been ruled by the ITAT to constitute Fees for Technical Services under Double Taxation Avoidance Agreements.2.Under most DTAAs, FTS taxation requires the transfer of technical know-how under the make-available principle.Which of the statements given above is/are correct?

Solution

News · ITAT Ruling Fees for Technical Services DTAA

With reference to international taxation and Double Taxation Avoidance Agreements (DTAAs), the 'Make-Available Clause' implies that:

Solution