https://www.taxtmi.com/acts?id=34176 Royalties paid between Contracting Parties may be taxed in the residence of the recipient but may also be taxed in the source state; where the beneficial owner is resident of the other Contracting Party the source tax on the gross amount is limited. The Article defines royalties broadly and excludes these rules when the beneficial owner's rights are effectively connected with a permanent establishment or fixed base in the source state, in which case business profits or independent personal services provisions apply. Non arm's length excess payments are treated separately, and treaty benefits are denied if one main purpose was to secure those benefits. en-us Fri, 28 Dec 2018 16:39:34 +0530 Thu, 21 Nov 2024 10:50:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=34176 Royalties paid between Contracting Parties may be taxed in the residence of the recipient but may also be taxed in the source state; where the beneficial owner is resident of the other Contracting Party the source tax on the gross amount is limited. The Article defines royalties broadly and excludes these rules when the beneficial owner's rights are effectively connected with a permanent establishment or fixed base in the source state, in which case business profits or independent personal services provisions apply. Non arm's length excess payments are treated separately, and treaty benefits are denied if one main purpose was to secure those benefits. Act-Rules DTAA Fri, 28 Dec 2018 16:39:34 +0530 https://www.taxtmi.com/acts?id=34176