Tax on royalties and technical service fees now attracts a specified flat rate for agreements concluded after the treaty change. Effective 1 April 2006 the amendment distinguishes agreements by date: agreements after 31 May 1997 but before 1 June 2005 remain under prior clause treatment; agreements made on or after 1 June 2005 attract a specified flat rate tax on income by way of royalty and on fees for technical services when such income is included in total income.
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Provisions expressly mentioned in the judgment/order text.
Tax on royalties and technical service fees now attracts a specified flat rate for agreements concluded after the treaty change.
Effective 1 April 2006 the amendment distinguishes agreements by date: agreements after 31 May 1997 but before 1 June 2005 remain under prior clause treatment; agreements made on or after 1 June 2005 attract a specified flat rate tax on income by way of royalty and on fees for technical services when such income is included in total income.
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