Royalties exclusive source taxation under DTAA; source territory holds the taxing right for use based payments. Royalties derived by a resident of one Contracting State from sources in the other Contracting State are taxable only in the source territory, granting an exclusive taxing right to that state. 'Royalty' covers consideration for the right to use copyrights, artistic and scientific works, cinematographic films, patents, models, designs, plans, secret processes or formulae, trade marks and similar rights, but excludes amounts relating to the operation of mines, quarries or other natural resources.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Royalties exclusive source taxation under DTAA; source territory holds the taxing right for use based payments.
Royalties derived by a resident of one Contracting State from sources in the other Contracting State are taxable only in the source territory, granting an exclusive taxing right to that state. "Royalty" covers consideration for the right to use copyrights, artistic and scientific works, cinematographic films, patents, models, designs, plans, secret processes or formulae, trade marks and similar rights, but excludes amounts relating to the operation of mines, quarries or other natural resources.
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