https://www.taxtmi.com/caselaws?id=328539 A Singapore tax resident licensing know-how on a principal-to-principal basis was treated as the beneficial owner of royalty and interest income for India-Singapore treaty purposes. Because the royalty arose from its own contractual rights and not as a nominee or conduit, the reduced 10% treaty rate under Article 12 applied. The interest was likewise regarded as beneficially owned by the recipient, so Article 11 relief at the reduced rate was available. Article 24 was construed as not denying treaty benefit merely because remittance to Singapore occurred in a later year, where the income was otherwise subject to tax in the residence State. en-us Fri, 15 Apr 2016 00:00:00 +0530 Tue, 07 Jun 2016 11:21:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=328539 A Singapore tax resident licensing know-how on a principal-to-principal basis was treated as the beneficial owner of royalty and interest income for India-Singapore treaty purposes. Because the royalty arose from its own contractual rights and not as a nominee or conduit, the reduced 10% treaty rate under Article 12 applied. The interest was likewise regarded as beneficially owned by the recipient, so Article 11 relief at the reduced rate was available. Article 24 was construed as not denying treaty benefit merely because remittance to Singapore occurred in a later year, where the income was otherwise subject to tax in the residence State. Case-Laws Income Tax Fri, 15 Apr 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=328539