Double taxation treaty amended to cap source tax on royalties at 10% and strengthen information exchange obligations. Amendments cap source taxation of royalties and fees for technical services at 10% of gross where the beneficial owner is resident of the other Contracting State, expand the definition of 'royalties,' require Belgium to allow reasonable executive and general administrative expense deductions for Indian resident permanent establishments, replace the Exchange of Information provision to mandate foreseeable relevant information exchange including bank and fiduciary-held data, and replace Aid and Assistance in Recovery with a mutual assistance in collection regime subject to specified limitations and safeguards.
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Provisions expressly mentioned in the judgment/order text.
Double taxation treaty amended to cap source tax on royalties at 10% and strengthen information exchange obligations.
Amendments cap source taxation of royalties and fees for technical services at 10% of gross where the beneficial owner is resident of the other Contracting State, expand the definition of "royalties," require Belgium to allow reasonable executive and general administrative expense deductions for Indian resident permanent establishments, replace the Exchange of Information provision to mandate foreseeable relevant information exchange including bank and fiduciary-held data, and replace Aid and Assistance in Recovery with a mutual assistance in collection regime subject to specified limitations and safeguards.
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