https://www.taxtmi.com/acts?id=4822 The treaty permits both residence and source taxation of royalties, but caps source taxation at 15 per cent where the recipient is the beneficial owner. The article defines royalties to cover payments for use of copyrights, patents, trademarks, designs, equipment, and industrial or commercial information. Royalties connected to a permanent establishment or fixed base are taxed under business profits or independent services rules instead. A special-relationship provision limits the treaty's application to arm's-length amounts, leaving excess payments taxable under domestic law. en-us Sat, 19 Jan 2008 22:45:54 +0530 Fri, 06 Mar 2009 16:13:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4822 The treaty permits both residence and source taxation of royalties, but caps source taxation at 15 per cent where the recipient is the beneficial owner. The article defines royalties to cover payments for use of copyrights, patents, trademarks, designs, equipment, and industrial or commercial information. Royalties connected to a permanent establishment or fixed base are taxed under business profits or independent services rules instead. A special-relationship provision limits the treaty's application to arm's-length amounts, leaving excess payments taxable under domestic law. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4822