IQVIA AG vs DCIT: DTAA Implications on Taxation of Online Market Research Reports

Author : skmcglobal 16068 | Published On : 26 Feb 2026

Taxability of Online Market Research Reports under DTAA: IQVIA AG vs DCIT highlights a crucial ruling on whether payments for online research reports constitute “royalty” or “fees for technical services” under the India–Switzerland DTAA. The tribunal examined if access to standardized reports amounts to transfer of copyright or technical know-how. It held that mere access to copyrighted material without rights to exploit or modify it does not qualify as royalty, impacting withholding tax obligations for cross-border digital services. This decision provides clarity for global research and data companies operating in India. SKMC Global assists businesses with DTAA interpretation, withholding tax advisory, cross-border structuring, and litigation support to ensure compliant and tax-efficient operations.