AAR : The payments received by SkillSoft Ireland Limited (“the Applicant”) would be characterized as ‘fees for technical services’ (“FTS”) under Article 12(3)(b) of the Agreement between the Government of the Republic of India and the Government of Ireland for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income(“India-Ireland Treaty”)

Authority For Advance Rulings (Income-Tax), New Delhi SkillSoft Ireland Ltd., In re Section 9 Justice V. S. Sirpurkar, Chairman And A.K. Tewary, Member A.A.R. No. 985 Of 2010 July 20, 2015 RULING A.K. Tewary, Member – The applicant is a Private Limited Company incorporated under the laws of Ireland. It is engaged in the business…

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