ITAT Rules Rothschild’s Intra-Group Advisory and Support Services Not Taxable as FTS Under India-UK DTAA

ITAT ruled that Rothschild's intra-group advisory and support services are not taxable as Fees for Technical Services (FTS) under the India-UK Double Taxation Avoidance Agreement (DTAA). The tribunal interpreted the provisions of the DTAA concerning FTS and concluded that the services provided within the Rothschild group did not meet the criteria for being taxed as such. This decision provides clarity on the taxability of intra-group services under the India-UK tax treaty, potentially impacting multinational companies with similar service arrangements.