https://www.taxtmi.com/acts?id=10346 Article 12 permits residence-state taxation of royalties while allowing source-state taxation subject to a reduced limitation when the beneficial owner is resident of the other Contracting State; competent authorities shall settle application of that limitation. Royalties are broadly defined to cover payments for use of intellectual property, equipment, and technical information. The limitation does not apply if the beneficial owner has a permanent establishment or fixed base in the source State and the royalties are effectively connected thereto, in which case Articles 7 or 15 govern. Deemed-source rules and arm's-length adjustment for related-party distortions are also provided. en-us Sat, 17 Jan 2009 18:36:16 +0530 Mon, 25 Nov 2024 14:23:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=10346 Article 12 permits residence-state taxation of royalties while allowing source-state taxation subject to a reduced limitation when the beneficial owner is resident of the other Contracting State; competent authorities shall settle application of that limitation. Royalties are broadly defined to cover payments for use of intellectual property, equipment, and technical information. The limitation does not apply if the beneficial owner has a permanent establishment or fixed base in the source State and the royalties are effectively connected thereto, in which case Articles 7 or 15 govern. Deemed-source rules and arm's-length adjustment for related-party distortions are also provided. Act-Rules DTAA Sat, 17 Jan 2009 18:36:16 +0530 https://www.taxtmi.com/acts?id=10346