https://www.taxtmi.com/acts?id=6288 Royalties may be taxed in the recipient's State, while the source State may also tax royalties arising there subject to a withholding tax limit when the recipient is the beneficial owner. Royalties are broadly defined to include payments for use of copyrights, trademarks, designs, plans, secret formulas, processes, equipment and technical information. If the beneficial owner carries on business through a permanent establishment or performs independent personal services from a fixed base and the royalties are effectively connected with that presence, business profits or independent personal services provisions apply. Related party excess payments are adjusted to arm's length amounts for treaty application. en-us Sat, 19 Jan 2008 22:45:54 +0530 Sat, 23 Nov 2024 11:55:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=6288 Royalties may be taxed in the recipient's State, while the source State may also tax royalties arising there subject to a withholding tax limit when the recipient is the beneficial owner. Royalties are broadly defined to include payments for use of copyrights, trademarks, designs, plans, secret formulas, processes, equipment and technical information. If the beneficial owner carries on business through a permanent establishment or performs independent personal services from a fixed base and the royalties are effectively connected with that presence, business profits or independent personal services provisions apply. Related party excess payments are adjusted to arm's length amounts for treaty application. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=6288