Withholding tax limits on cross-border passive income reduce source taxation where the recipient is the beneficial owner. Modification of the India-Netherlands tax Convention implements reduced source taxation limits where the recipient is the beneficial owner: dividends and interest may be taxed in the source State but withholding is capped when the recipient is the beneficial owner; Article 12 is redrafted to define royalties and fees for technical services, to limit source taxation of such payments subject to transitional rates and exceptions, and to preserve the exclusion where income is effectively connected with a permanent establishment or fixed base.
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.
Withholding tax limits on cross-border passive income reduce source taxation where the recipient is the beneficial owner.
Modification of the India-Netherlands tax Convention implements reduced source taxation limits where the recipient is the beneficial owner: dividends and interest may be taxed in the source State but withholding is capped when the recipient is the beneficial owner; Article 12 is redrafted to define royalties and fees for technical services, to limit source taxation of such payments subject to transitional rates and exceptions, and to preserve the exclusion where income is effectively connected with a permanent establishment or fixed base.
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