https://www.taxtmi.com/caselaws?id=204766 A composite contract granting restricted rights to use proprietary software, installation, perpetual licence, training, support, scientific know-how and equipment was characterised as royalty under Article 12 of the India-Sri Lanka Tax Treaty because it involved payment for use of scientific work, model, plan, equipment and experience without transfer of ownership or intellectual property. In the absence of a specific treaty article for fees for technical services, the residuary article could apply only where income was not otherwise covered, but that issue did not arise once the receipts were classified as royalties. The consideration was therefore taxable as royalty income, not as business profits under Article 7. en-us Mon, 16 May 2011 00:00:00 +0530 Thu, 04 Jul 2013 12:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=204766 A composite contract granting restricted rights to use proprietary software, installation, perpetual licence, training, support, scientific know-how and equipment was characterised as royalty under Article 12 of the India-Sri Lanka Tax Treaty because it involved payment for use of scientific work, model, plan, equipment and experience without transfer of ownership or intellectual property. In the absence of a specific treaty article for fees for technical services, the residuary article could apply only where income was not otherwise covered, but that issue did not arise once the receipts were classified as royalties. The consideration was therefore taxable as royalty income, not as business profits under Article 7. Case-Laws Income Tax Mon, 16 May 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=204766