https://www.taxtmi.com/acts?id=51358 Article 12 allocates primary taxation of royalties to the residence State of the beneficial owner, defines royalties broadly to include payments for use of intellectual property and technical information, and deems royalties to arise where the use occurs. Exceptions permit source-State taxation where the beneficial owner is a connected person benefiting from a special tax regime, where expatriated-entity rules apply to royalties paid to connected companies, and where royalties are effectively connected with a permanent establishment, in which case Article 7 applies. Arm's-length adjustments limit Treaty relief for amounts exceeding market value. en-us Wed, 21 May 2025 15:40:17 +0530 Wed, 21 May 2025 15:40:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=51358 Article 12 allocates primary taxation of royalties to the residence State of the beneficial owner, defines royalties broadly to include payments for use of intellectual property and technical information, and deems royalties to arise where the use occurs. Exceptions permit source-State taxation where the beneficial owner is a connected person benefiting from a special tax regime, where expatriated-entity rules apply to royalties paid to connected companies, and where royalties are effectively connected with a permanent establishment, in which case Article 7 applies. Arm's-length adjustments limit Treaty relief for amounts exceeding market value. Act-Rules DTAA Wed, 21 May 2025 15:40:17 +0530 https://www.taxtmi.com/acts?id=51358