Indian Tax Tribunal Holds Bandwidth Services Not Treated as Taxable Royalties under Tax Treaty with Singapore

A decision of the Mumbai Income Tax Appellate Tribunal was published on 8 June 2019 concerning whether payments for bandwidth services may be considered taxable royalties under the 1994 India-Singapore tax treaty. The case involved India-based Reliance Jio Infocomm Ltd. (RJIL), which entered into a bandwidth services agreement with Singapore-based Reliance Jio Infocomm Pte. Ltd (RJIPL). Under the terms of the agreement, RJIL remitted USD 1,345,500 to RJIPL for the provision of bandwidth serv…