Royalties

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....beneficial owner of the royalties, the tax so charged shall not exceed 15 per cent of the gross amount of the royalties provided that such royalties are payable : (i) in the case of Philippines, by an enterprise which is registered with the Board of Investment, and (ii) in the case of India, by an enterprise in pursuance of any collaboration agreement approved by the Government o....

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....tuated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 5. Royalties shall be deemed to arise in a Contrac....