Australia's Federal Court has published an 11 October 2018 decision of the Full Court on whether service payments received by an Indian company from its Australian clients that are royalties for the purposes of Article 12 (Royalties) of the 1991 Australia-India tax treaty but are not otherwise royalties as defined under Australian law, may be considered assessable income in Australia.
The case involves service payments made to Satyam Computer Services Limited (Satyam), which under the provi…