Domestic Law Amendments on Royalties Don't Affect Double Taxation Treaties: Misinterpretations Don't Change International Agreements.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Royalty u/s 9(1)(vi) read with DTAA - It is fallacious to assume that any change made to domestic law to rectify a situation of mistaken interpretation can spontaneously further their case in an international treaty. Therefore, mere amendment to Section 9(1)(vi) cannot result in a change - HC....