https://www.taxtmi.com/acts?id=17111 Royalties arising in a Contracting State may be taxed in the recipient's resident State but may also be taxed in the source State; if the recipient is the beneficial owner, the source State's tax on gross royalties shall not exceed ten per cent. Royalties are broadly defined to include payments for use of copyrights, films, patents, trade marks, designs, processes, equipment, and know how. If the beneficial owner carries on business through a permanent establishment or fixed base in the source State and the rights are effectively connected, Article 7 or Article 15 applies. Special relationships that inflate royalties trigger arm's length adjustment, leaving excess taxable under domestic law. en-us Thu, 31 Jan 2013 16:33:34 +0530 Tue, 26 Nov 2024 16:42:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=17111 Royalties arising in a Contracting State may be taxed in the recipient's resident State but may also be taxed in the source State; if the recipient is the beneficial owner, the source State's tax on gross royalties shall not exceed ten per cent. Royalties are broadly defined to include payments for use of copyrights, films, patents, trade marks, designs, processes, equipment, and know how. If the beneficial owner carries on business through a permanent establishment or fixed base in the source State and the rights are effectively connected, Article 7 or Article 15 applies. Special relationships that inflate royalties trigger arm's length adjustment, leaving excess taxable under domestic law. Act-Rules DTAA Thu, 31 Jan 2013 16:33:34 +0530 https://www.taxtmi.com/acts?id=17111