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India: Payments for bandwidth services not royalties taxable in India under the India-Singapore treaty

Delhi High Court decision

August 2, 2024

The Delhi High Court held that an expansion of the term “royalty” under domestic tax law occurring after the India-Singapore income tax treaty was entered into cannot be incorporated into or otherwise affect the interpretation of that term under the treaty in a manner that clearly broadens the scope of taxation under the treaty.

The taxpayer, a Singapore resident, was engaged in the business of providing bandwidth services. The tax authority argued that payments received by the taxpayer from Indian customers were taxable under the treaty as process or equipment royalties. Although under the definitions provided in the treaty, and applying the domestic law in effect at the time the treaty was entered into, the payments would not have been considered process or equipment royalties taxable in India under the treaty, the Finance Act, 2012 amended the term “process” such that the payments could be treated as royalties taxable in India. The court found, however, that the subsequent amendment could not be taken into account in interpreting the treaty and thus that the payments were not royalties subject to tax in India under the treaty.

The case is: CIT v. Telstra Singapore Pte Limited

Read an August 2024 report prepared by the KPMG member firm in India

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