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MasterCard Interface Processor constitutes PE; fees for processing card payments taxable as business income

June 13, 2018[2018] 94 195 (AAR - NewDelhi)/[2018] 406 ITR 43 (AAR - NewDelhi)/[2018] 303 CTR 305 (AAR - NewDelhi)

IT/ILT: Where Singapore based MasterCard Asia Pacific, incorporates an Indian subsidiary which owns and maintains MasterCard Interface Processor placed at customers' locations in India for processing of electronic payment transactions using MasterCards global network and infrastructure, part of fees received/to be received by applicant from Indian Customers would be classified as royalty; however, since it is effectively connected to PE, it would be taxed under article 7 and not under article 12 of India-Singapore DTAA

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