https://www.taxtmi.com/acts?id=16815 Article 12 permits taxation of royalties both in the source State and in the resident State of the beneficial owner, with a reduced withholding tax when the beneficial owner is resident in the other Contracting State. It defines royalties to include payments for use or rights to use intellectual property, equipment, and technical information. Royalties effectively connected to a permanent establishment or fixed base are taxed under business profits or independent personal services provisions. Transactions between related parties are limited to arm's-length amounts for the Article's application. en-us Tue, 31 Jul 2012 13:02:35 +0530 Wed, 27 Nov 2024 13:09:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=16815 Article 12 permits taxation of royalties both in the source State and in the resident State of the beneficial owner, with a reduced withholding tax when the beneficial owner is resident in the other Contracting State. It defines royalties to include payments for use or rights to use intellectual property, equipment, and technical information. Royalties effectively connected to a permanent establishment or fixed base are taxed under business profits or independent personal services provisions. Transactions between related parties are limited to arm's-length amounts for the Article's application. Act-Rules DTAA Tue, 31 Jul 2012 13:02:35 +0530 https://www.taxtmi.com/acts?id=16815