https://www.taxtmi.com/acts?id=5182 Article 12 allocates taxation of royalties to the recipient's State of residence while allowing the source State to tax royalties arising there, subject to a maximum withholding. It defines royalties to include payments for use of copyrighted works, patents, trademarks, designs, equipment and technical information. Royalties connected with a recipient's permanent establishment or fixed base in the source State are taxed under Articles 7 or 14. Royalties are deemed to arise where the payer is resident or where a payer's permanent establishment incurred the liability. Payments exceeding an arm's-length amount due to special relationships are limited to the arm's-length portion for treaty purposes. en-us Sat, 19 Jan 2008 22:45:54 +0530 Thu, 28 Nov 2024 12:15:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5182 Article 12 allocates taxation of royalties to the recipient's State of residence while allowing the source State to tax royalties arising there, subject to a maximum withholding. It defines royalties to include payments for use of copyrighted works, patents, trademarks, designs, equipment and technical information. Royalties connected with a recipient's permanent establishment or fixed base in the source State are taxed under Articles 7 or 14. Royalties are deemed to arise where the payer is resident or where a payer's permanent establishment incurred the liability. Payments exceeding an arm's-length amount due to special relationships are limited to the arm's-length portion for treaty purposes. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5182