International Tax - Royalty and Fee for Technical Services
Learn how to interpret Article 12 - Royalty and Fee for Technical Services, Right of Source and Residence State to tax
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56
students
3 hours
content
Sep 2016
last update
$19.99
regular price
What you will learn
Understand which payments amount to Royalty and Fee for Technical Services
Identify the Rights of Source State (India) and State of Residence to tax Royalty and Fee for Technical Services
Apply steps to be followed to ascertain Tax implications on Royalty and Fee for Technical Services and ascertaining withholding tax rates in Source State (India)
Know the conditions applicable to claim Treaty benefits – Test of beneficial ownership and proof of Residence
Understand when Royalty and Fee for Technical Services Arise in India under local laws/ Applicable Treaty
Comparison of Royalty under the Indian Income Tax Act, OECD & UN Model
Classify various payments into Royalty/ Fee for technical Services, including – a. Payment for Imparting of information b. Transfer of all or any rights c. Copyright of literary, artistic or scientific work d. Dry and Wet Lease amount to use of Equipment
Ascertain the Tax deductibility in hands of Payer of Royalty in Source State
Understand the meaning/exclusions of Fee for technical (Included) Services under India USA Treaty
When would Fee for technical Services be considered as “Make available”
Taxation of Royalty and for technical Services effectively connected to a PE
How would the tax apply to excess payments of Royalty and Fee for technical Services to related Enterprise
Impact of Most Favored Nation Clause (MFN Clause) on taxation of Royalty and Fee for technical Services
Related Topics
926820
udemy ID
8/9/2016
course created date
10/21/2021
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