MasterCard Interface Processor constitutes PE; fees for processing card payments taxable as business income

IT/ILT : Where Applicant MasterCard Asia Pacific is a Singapore based company engaged in processing of electronic payment transactions has an Indian subsidiary which owns and maintains MasterCard Interface Processor placed at Customers' locations in India, a part of fees received/to be received by Applicant from Indian Customers would be classified as royalty; however, since it is effectively connected to PE, it would be taxed under Article 7 and not under Article 12

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