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of <h1>Section 115BBF: India Aligns with BEPS Action 5 to Tax Patent Royalties at 10% for R&D in India</h1> Action Plan 5 of the Base Erosion and Profit Shifting (BEPS) initiative focuses on countering harmful tax practices. It is a minimum standard subject to peer review to ensure fair implementation. The OECD Forum on Harmful Tax Practices reviews preferential tax regimes, monitors transparency through information exchange, and assesses substantial activities in low-tax jurisdictions. Six categories of tax rulings are identified for transparency. The NTJ standard facilitates information exchange among 12 low-tax jurisdictions. In India, Section 115BBF of the Income Tax Act aligns with BEPS Action 5, taxing patent royalties at 10% if substantial R&D is done in India.
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