Tax on dividends, royalty and technical service fees: specified withholding rates apply to foreign companies' cross-border income. Non-residents and foreign companies receive specified categories of passive and service income taxed at fixed prescribed rates while their remaining total income is taxed at rates in force; royalty and technical-service receipts under approved or policy-consistent agreements are similarly subject to specified rates, with royalties for certain transfers of copyright or computer software treated under this regime. Definitions for computer software, royalty and fees for technical services are specified, deductions for listed allowances are disallowed for such income, and special rules control deduction entitlement and filing where income consists solely of these receipts.
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.
Tax on dividends, royalty and technical service fees: specified withholding rates apply to foreign companies' cross-border income.
Non-residents and foreign companies receive specified categories of passive and service income taxed at fixed prescribed rates while their remaining total income is taxed at rates in force; royalty and technical-service receipts under approved or policy-consistent agreements are similarly subject to specified rates, with royalties for certain transfers of copyright or computer software treated under this regime. Definitions for computer software, royalty and fees for technical services are specified, deductions for listed allowances are disallowed for such income, and special rules control deduction entitlement and filing where income consists solely of these receipts.
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