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V2604-14 6 October 2014 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · cánones

Online course fees in India may be treated as royalties

A Spanish company asks about the tax treatment of online course sales to Indian customers and the hiring of professionals there. The DGT examines whether payments for courses constitute business profits or royalties under the Spain-India tax treaty.

The question raised

1. Tax treatment for Value Added Tax and Corporate Income Tax purposes, regarding both the provision of services by the entity to companies or entities in India, and the services provided by Indian companies or professionals to the company.

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