https://www.taxtmi.com/acts?id=5785 The DTAA permits both the residence and source State to tax royalties but caps source State tax at ten per cent of gross royalties when the recipient is the beneficial owner. Royalties are broadly defined to cover payments for copyrights, patents, trademarks, designs, equipment and technical information. If the beneficial owner carries on business in the source State through a permanent establishment and the royalties are effectively connected with that permanent establishment, Article 7 applies. Payments deemed to arise where the payer or a permanent establishment is situated, and special-relationship rules limit taxation to arm's-length amounts. en-us Sat, 19 Jan 2008 22:45:54 +0530 Fri, 06 Mar 2009 17:11:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5785 The DTAA permits both the residence and source State to tax royalties but caps source State tax at ten per cent of gross royalties when the recipient is the beneficial owner. Royalties are broadly defined to cover payments for copyrights, patents, trademarks, designs, equipment and technical information. If the beneficial owner carries on business in the source State through a permanent establishment and the royalties are effectively connected with that permanent establishment, Article 7 applies. Payments deemed to arise where the payer or a permanent establishment is situated, and special-relationship rules limit taxation to arm's-length amounts. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5785