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How to interpret nexus rule for India’s tax treaties

The 2010 amendment to India-Finland tax treaty appears to make the scope of taxation of fee for technical services even more restrictive such that fee for technical services paid by Indian tax resident to Finnish tax resident for services rendered in Finland is not taxable in India. However, K Swaminathan of Lakshmi Kumaran & Sridharan provides six case studies that show the treaty actually enhances the scope rather than restricting it.

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