Focus (Forum & Focus)
Apr. 16, 2009
A Bogus Payment Plan
Decisions by Indian tax authorities create considerable risks for U.S. software companies operating in India as their income is inappropriately taxed as royalties.
FOCUS COLUMN
By Gary D. Sprague and Kavan Gene Lee In the last few decades, various jurisdictions' tax characterization of income from software transactions has generally evolved with the industry. In India, courts have overwhelmingly adopted the United States' and the Organization for Economic Cooperation and Development's substance-over-form approach, under which receipts for perpetual licenses for user applications are characterized as income f...For only $95 a month (the price of 2 article purchases)
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