Q12 · UPSC current affairs · 29 August 2026 · News · ITAT Ruling Fees for Technical Services DTAA

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

A All managerial services rendered abroad are automatically exempt from domestic taxation.
B FTS is taxable only if the service provider enables the recipient to independently apply the technology or skill later.
C The source country has absolute right to tax royalty without any restriction.
D Technical know-how must be transferred exclusively through government-to-government channels.

Correct answer: (b) FTS is taxable only if the service provider enables the recipient to independently apply the technology or skill later.

Explanation

Option B is correct because the make-available principle dictates that FTS is taxable only if the service provider enables the recipient to independently apply the technology or skill later. Options A, C, and D do not correctly define the make-available clause.

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