https://www.taxtmi.com/acts?id=45515 Article 12 permits taxation of royalties by the recipient's State and also by the State of source subject to prescribed limits; it defines royalties to include payments for use or right to use intellectual property, equipment, technical information, films and related services, while excluding certain services linked to sales, rentals for international transport, teaching, personal services, employee remuneration and specified professional services. Royalties connected to a permanent establishment or fixed base are taxed under business profits or independent personal services rules, and amounts inflated by special relationships are limited to arm's length consideration for the Article's purposes. en-us Fri, 18 Oct 2024 15:32:48 +0530 Fri, 18 Oct 2024 15:32:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45515 Article 12 permits taxation of royalties by the recipient's State and also by the State of source subject to prescribed limits; it defines royalties to include payments for use or right to use intellectual property, equipment, technical information, films and related services, while excluding certain services linked to sales, rentals for international transport, teaching, personal services, employee remuneration and specified professional services. Royalties connected to a permanent establishment or fixed base are taxed under business profits or independent personal services rules, and amounts inflated by special relationships are limited to arm's length consideration for the Article's purposes. Act-Rules DTAA Fri, 18 Oct 2024 15:32:48 +0530 https://www.taxtmi.com/acts?id=45515