https://www.taxtmi.com/caselaws?id=331954 Payments for digital broadcasting of television content through a foreign satellite transponder were not royalty under Article 12(3) of the India-Thailand tax treaty because the foreign party provided broadcasting services using equipment under its control, while the assessee only supplied the programme source signal. The arrangement did not involve exploitation of copyright in a film or television broadcast, nor did it give the payer the use of, or right to use, industrial, commercial or scientific equipment. On that interpretation, the payment fell outside the treaty definition of royalty and was not taxable as such. en-us Fri, 29 Jul 2016 00:00:00 +0530 Tue, 06 Sep 2016 13:23:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=331954 Payments for digital broadcasting of television content through a foreign satellite transponder were not royalty under Article 12(3) of the India-Thailand tax treaty because the foreign party provided broadcasting services using equipment under its control, while the assessee only supplied the programme source signal. The arrangement did not involve exploitation of copyright in a film or television broadcast, nor did it give the payer the use of, or right to use, industrial, commercial or scientific equipment. On that interpretation, the payment fell outside the treaty definition of royalty and was not taxable as such. Case-Laws Income Tax Fri, 29 Jul 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=331954