https://www.taxtmi.com/caselaws?id=65174 Royalty payments made through Hindustan Aeronautics Ltd. were treated as payments by the Government of India for treaty purposes because the agreement appointed the company only as the Government's agent for implementation and performance. On that basis, the payer was not a separate non-government person acting on its own account, so the higher treaty rate did not apply. The India-UK Double Tax Avoidance Agreement therefore applied the lower royalty rate where the Government of India was the payer, resulting in taxation at 15 per cent rather than 20 per cent. en-us Tue, 15 Feb 2005 00:00:00 +0530 Mon, 14 Feb 2011 10:42:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=65174 Royalty payments made through Hindustan Aeronautics Ltd. were treated as payments by the Government of India for treaty purposes because the agreement appointed the company only as the Government's agent for implementation and performance. On that basis, the payer was not a separate non-government person acting on its own account, so the higher treaty rate did not apply. The India-UK Double Tax Avoidance Agreement therefore applied the lower royalty rate where the Government of India was the payer, resulting in taxation at 15 per cent rather than 20 per cent. Case-Laws Income Tax Tue, 15 Feb 2005 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=65174