The ‘synthesised’ version of the UK-India double taxation agreement has been modified to add a new condition to the provisions covering the double taxation of royalties and fees. Article 13 deals with royalties and fees for technical services arising in one country and paid to a resident in the other.
A new paragraph inserted into Article 13 adds a new cap on the amount of tax on royalties and fees that may be charged in the state in which they arise, where the beneficial owner of the royalties or fees is resident in the other state.
The ‘synthesised’ version of the UK-India double taxation agreement has been modified to add a new condition to the provisions covering the double taxation of royalties and fees. Article 13 deals with royalties and fees for technical services arising in one country and paid to a resident in the other.
A new paragraph inserted into Article 13 adds a new cap on the amount of tax on royalties and fees that may be charged in the state in which they arise, where the beneficial owner of the royalties or fees is resident in the other state.