Taxation of Royalties: domestic law amendments cannot override DTAA interpretation; telecommunication payments not royalties. The court held that unilateral domestic amendments to the statutory definition of royalty cannot alter the meaning of that term in a DTAA; treaty terms ... Summary
Taxation of Royalties: domestic law amendments cannot override DTAA interpretation; telecommunication payments not royalties.
The court held that unilateral domestic amendments to the statutory definition of royalty cannot alter the meaning of that term in a DTAA; treaty terms are to be interpreted by their plain meaning, guided by international law principles, OECD commentary, and precedents, and payments for telecommunication services or satellite transponder capacity do not qualify as royalties under the relevant DTAA.
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