India has reduced royalty rates for crude oil and natural gas production, aiming to accelerate domestic exploration and output. The biggest cuts apply to deepwater and ultra-deepwater fields, where the new framework can offer zero royalty for an initial period. The policy is designed to make difficult reserves more economically viable and attract investment into domestic energy supply.
The Supreme Court dismissed the income tax department’s review petitions over whether payments for foreign software by Indian users should be taxed as royalty. Reaffirming its March 2021 ruling, the court said end-user licenses do not transfer copyright, so such payments are not royalty. The decision is expected to provide substantial tax certainty and relief to Indian companies buying software.
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The Supreme Court has settled a long-running tax classification debate, ruling that payments made by resident end users for the resale or use of computer software generally cannot be labelled as “royalty” under tax treaties. Instead, such transactions are treated as procurement of goods, reshaping how software-related income is taxed under the DTAA framework.
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