https://www.taxtmi.com/caselaws?id=213490 Payments under a research and development cost allocation agreement were treated as royalty rather than reimbursement because the amounts were linked to use of the developed technology, not a genuine sharing of research costs. The arrangement gave consideration for use of a process or scientific experience, satisfying the royalty definition under section 9(1)(vi) and Article 12(3) of the treaty. The reimbursement character was rejected, and tax had to be deducted at source at the prescribed rate. en-us Thu, 22 Mar 2012 00:00:00 +0530 Fri, 17 Aug 2012 11:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=213490 Payments under a research and development cost allocation agreement were treated as royalty rather than reimbursement because the amounts were linked to use of the developed technology, not a genuine sharing of research costs. The arrangement gave consideration for use of a process or scientific experience, satisfying the royalty definition under section 9(1)(vi) and Article 12(3) of the treaty. The reimbursement character was rejected, and tax had to be deducted at source at the prescribed rate. Case-Laws Income Tax Thu, 22 Mar 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=213490