https://www.taxtmi.com/acts?id=6318 The treaty permits residence taxation of royalties while allowing source taxation subject to a maximum withholding cap; royalties are broadly defined to include payments for use of intellectual property, equipment, and industrial information. If the recipient's permanent establishment in the source State is effectively connected with the royalties, business profits rules apply instead. Royalties are deemed to arise where the payer is resident or where they are borne by a permanent establishment, and where related-party pricing elevates payments above arm's-length the treaty applies only to the arm's-length portion, leaving excess amounts taxable under domestic law. en-us Sat, 19 Jan 2008 22:45:54 +0530 Mon, 25 Nov 2024 12:15:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=6318 The treaty permits residence taxation of royalties while allowing source taxation subject to a maximum withholding cap; royalties are broadly defined to include payments for use of intellectual property, equipment, and industrial information. If the recipient's permanent establishment in the source State is effectively connected with the royalties, business profits rules apply instead. Royalties are deemed to arise where the payer is resident or where they are borne by a permanent establishment, and where related-party pricing elevates payments above arm's-length the treaty applies only to the arm's-length portion, leaving excess amounts taxable under domestic law. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=6318