India Court Holds MFN Clause in Protocol to French Tax Treaty Incorporates Scope of FTS under UK Treaty
The Delhi High Court recently published its decision concerning whether the MFN clause included in the final protocol to the 1992 income and capital tax treaty with France may incorporate the more favorable scope of fees for technical services (FTS) under the 1993 income and capital tax treaty with the UK. The case involved Steria (India) Ltd. (Steria India), which entered into a management ser…
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