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Management Support Services vis-à-vis Other Income – An Analysis on position under Treaties
Introduction:
In our previous article[1], the concept of taxability of management support services (for brevity ‘MSS”) under fee for technical services (for brevity ‘FTS’ or ‘FIS’) clause has been analyzed in detail.
We have concluded that MSS is not taxable under Article 12, since the term ‘managerial’ is not included in the definition of FTS/FIS. However, we cannot conclude the non-taxability of such income only on examining Article 12. The examining of taxation of such income will not be completed without analyzing the taxability of such services under Articles which deals with ‘Other Income’.