Withholding tax on royalties reduced for payments tied to post-agreement rights, aligning India-Canada treatment under the treaty. The DTAA between India and Canada was amended to apply a reduced rate of tax to royalties and fees for technical services where the right is first granted or the contract is signed after 12-12-1988; India notified the reduced rate and Canada issued a remission order providing reciprocal relief by remitting the excess of taxes, interest and penalties payable over the tax that would have been payable under the reduced rate.
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Provisions expressly mentioned in the judgment/order text.
Withholding tax on royalties reduced for payments tied to post-agreement rights, aligning India-Canada treatment under the treaty.
The DTAA between India and Canada was amended to apply a reduced rate of tax to royalties and fees for technical services where the right is first granted or the contract is signed after 12-12-1988; India notified the reduced rate and Canada issued a remission order providing reciprocal relief by remitting the excess of taxes, interest and penalties payable over the tax that would have been payable under the reduced rate.
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