https://www.taxtmi.com/acts?id=5937 Royalties paid to a resident of the other Contracting State may be taxed in the recipient's State, while the source State may also tax those royalties subject to a cap. Royalties include payments for use of intellectual property, equipment, and technical information. If the recipient carries on business in the source State through a permanent establishment or fixed base and the royalty is effectively connected, business profits provisions apply instead. Royalties are sourced to the payer's State or to the State of the permanent establishment that incurred the liability. Where related party arrangements inflate royalties, only the arm's length amount is governed by the Article. en-us Sat, 19 Jan 2008 22:45:54 +0530 Fri, 06 Mar 2009 17:33:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5937 Royalties paid to a resident of the other Contracting State may be taxed in the recipient's State, while the source State may also tax those royalties subject to a cap. Royalties include payments for use of intellectual property, equipment, and technical information. If the recipient carries on business in the source State through a permanent establishment or fixed base and the royalty is effectively connected, business profits provisions apply instead. Royalties are sourced to the payer's State or to the State of the permanent establishment that incurred the liability. Where related party arrangements inflate royalties, only the arm's length amount is governed by the Article. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5937