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    <description>Whether fees for live transmission of sporting events constitute royalty under the tax provision hinging on Explanation 2 was considered: the reasoning is that a live telecast lacks the minimum requirement of creativity to attract copyright protection and therefore does not qualify as a transferred copyright right, with the consequence that payments confined to live-feed exhibition without recording or re-telecast rights cannot be treated as royalty. Distinction between copyright and broadcast right was applied to conclude that transient live transmission rights, limited in time and scope, do not create enduring proprietary benefits and thus are non-royalty receipts.</description>
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