Training Services and access to standard hotel software aren't FTS under India-Netherland DTAA

IT/ILT: Consideration received by assessee for providing training services to Indian Hotels could not be held as FTS under article 12(5)(a) of India-Netherland tax treaty, as neither training services rendered by assessee to Indian Hotels could be held to be technical services, nor same could have been characterized as 'ancillary and subsidiary' services as per article 12(5)(a)

from www.taxmann.com Latest Case Laws https://ift.tt/2Lnr3Ff