Characterization of Software Transactions for Tax Treaty Purposes – The Infrasoft (2013) Case

Journal
India
Bulletin for International Taxation 2014 (Volume 68), No. 4/5
This article discusses the recent decision of the Delhi High Court in the case of Director of Income Tax v. Infrasoft Ltd. (2013), which distinguished between a transfer of copyright in the software and a transfer of the right to use the copyrighted material.