The Kolkata Income Tax Appellate Tribunal has recently issued a ruling on whether management support services are considered fees for technical services (FTS) under the 2010 Finland-India tax treaty. The case involved Finnish-based Outotec OYJ, a metal and mineral processing technologies company, and its group company, Outotec India Pvt Ltd.
In the 2009-10 tax year, Outotec OYJ received payments for management support and related services provided to Outotec India amounting to approximately …