Royalties
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....royalties is a resident of the other Contracting State, the tax so charged shall not exceed: a) 15 per cent of the gross amount of the royalties arising from the use or the right to use trademarks; b) 10 per cent of the gross amount of the royalties in all other cases.] 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for t....
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....right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such cases the provisions of Article 7 or Article 14, as the case may be, shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is a resident of that State. Where, however, the person paying the royalties, whether he is a re....
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....he last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Convention. *************** NOTES:- 1. Substituted vide Notification No. 39/2026 dated 30-03-2026 before it was read as, "2. However, such royaltie....
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....ein, and the right of property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such case the provisions of Article 7 shall apply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political sub-division, a local authority or a resident of that State. Where, however, the person payin....
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