In a recent ruling, India's Authority for Advance Rulings (AAR) has held that the following services may be considered taxable fees for technical services (FTS) under the 1994 China-India income tax treaty even if not rendered in the other Contracting State:
- Identification and evaluation of products and suppliers;
- Generation of new products and ideas;
- Market research;
- Resolution of pricing issues;
- Safety/endurance tests;
- Review of quality systems; and
- Interaction with vendors
The positio…