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        <h1>Income Tax Bill 2025: Clause 59 Targets Non-Resident Royalties with New Compliance Rules Aligning with Global Standards.</h1> Clause 59 of the Income Tax Bill, 2025, addresses the taxation of royalties and fees for technical services received by non-residents from Indian sources, categorizing it under 'Profits and gains of business or profession.' It mandates that such income be connected with a permanent establishment in India to prevent tax avoidance. The clause closely aligns with Section 44DA of the Income Tax Act, 1961, but introduces updated compliance requirements reflecting international tax practices. Non-residents must maintain proper documentation and undergo audits, and the provision may impact tax planning and dispute resolution regarding income characterization and permanent establishment existence.

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