Limitation on taxation of royalties and technical fees under the India Belgium treaty: capped source taxation and narrowed royalty definition. The Central Government amended Article 12 of the India-Belgium tax agreement to allow source taxation of royalties and fees for technical services while limiting the tax charged where the beneficial owner resides in the other Contracting State by imposing a fixed ceiling, effective in each State from the respective specified dates. It also replaced the definition of 'royalties' to include payments for use of or rights to copyrights (including cinematograph films), patents, trademarks, designs, models, plants, secret formulas or processes, and information on industrial, commercial or scientific experience.