Royalty definition clarifies taxable consideration for transfer, use, imparting of intellectual property and related services. Royalty for income-tax purposes means consideration, including lump-sum payments (excluding amounts chargeable as capital gains), for transfer or licensing of rights, imparting information about working or use, use of patents, inventions, designs, trademarks and similar property, imparting technical or scientific knowledge or skills, use or right to use equipment (subject to exclusions), and rendering services connected with those activities; royalty applies regardless of payer possession, use, or location of the subject matter, and a patent-specific definition excludes consideration for sale of products made using the patented process or article.
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Provisions expressly mentioned in the judgment/order text.
Royalty definition clarifies taxable consideration for transfer, use, imparting of intellectual property and related services.
Royalty for income-tax purposes means consideration, including lump-sum payments (excluding amounts chargeable as capital gains), for transfer or licensing of rights, imparting information about working or use, use of patents, inventions, designs, trademarks and similar property, imparting technical or scientific knowledge or skills, use or right to use equipment (subject to exclusions), and rendering services connected with those activities; royalty applies regardless of payer possession, use, or location of the subject matter, and a patent-specific definition excludes consideration for sale of products made using the patented process or article.
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