The Delhi High Court recently issued a decision concerning whether the sale of foreign-owned intangible assets registered and licensed in India is taxable in India. The case involved Australia-based CUB Pty Ltd (formerly Foster's Australia).
In 2006, the Foster's Group underwent a restructuring that involved a sale purchase agreement with SAB Miller, which included the grant of exclusive and perpetual license in relation to Foster’s intellectual property confined to India. As part of the sa…