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Informative

Supreme Court Reopens IBM India Case to Decide Whether Payments to IBM Philippines Are Taxable as Technical Services Despite DTAA Protection

Update / Judgement Date

04 Jul 2025

Source

Taxscan

Author

Team — WCP Legal Desk

Reading Time

1 min read

International TaxationOther Legal Matters

The Supreme Court has reopened the IBM India case to decide whether "payments to IBM Philippines are taxable as technical services, despite DTAA protection." The apex court's decision signals that it will once again examine a complex issue of international taxation. The ruling will have a profound impact on companies that have inter-company payments for technical services, especially when a DTAA is in place.