India Income Tax Appellate Tribunal Holds Payments for Database Access Not Taxable Royalties Under Tax Treaty with U.S.

The Delhi Income Tax Appellate Tribunal (ITAT) recently issued an order regarding the tax treatment of payments for database access under the 1989 tax treaty with the United States. The case involved U.S.-based Dow Jones & Company Inc. (Dow Jones), which engaged with Dow Jones Consulting India Private Limited (DJCIPL) on a principal-to-principal basis for distributing Dow Jones products in the Indian market. This includes providing information products and services containing global busin…