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ThynkTax /Tax Reference /Case Laws /Verizon Singapore

Verizon Singapore

High Court·2024·TDS
Facts

Verizon Singapore provided telecommunications and cloud services to Indian subscribers.

Issue

Whether payments constitute royalty or FTS under India-Singapore DTAA, triggering Section 195 TDS?

Held

Standard data transmission and cloud computing service payments are not royalty or FTS - they are business profits, taxable only if PE in India.

Ratio

Bandwidth and connectivity = business profits, not royalty.

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