https://www.taxtmi.com/acts?id=5002 Royalties arising in one Contracting State and paid to a resident of the other may be taxed in the recipient's State, while the State in which the royalties arise may also tax those payments subject to a source tax cap. The Article defines royalties to include payments for the use of copyrights, patents, trade marks, designs, secret formulas, industrial equipment and related information. The source tax limitation does not apply if the recipient carries on business in the source State through a permanent establishment or fixed base and the royalties are effectively connected with that establishment. Special relationship adjustments limit the Convention's application to arm's length amounts. en-us Sat, 19 Jan 2008 22:45:54 +0530 Fri, 06 Mar 2009 18:09:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5002 Royalties arising in one Contracting State and paid to a resident of the other may be taxed in the recipient's State, while the State in which the royalties arise may also tax those payments subject to a source tax cap. The Article defines royalties to include payments for the use of copyrights, patents, trade marks, designs, secret formulas, industrial equipment and related information. The source tax limitation does not apply if the recipient carries on business in the source State through a permanent establishment or fixed base and the royalties are effectively connected with that establishment. Special relationship adjustments limit the Convention's application to arm's length amounts. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5002