Amendment of the provisions relating to rate of tax on royalties and fees for technical services under the D.T.A.A. with Canada

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..... anada was signed on 30th October, 1985 and notified on 25th September, 1986 (See [1987] 164 ITR (St.) 87). Para 2 of article 13 of the agreement provides the rate of taxation at 30 per cent. in respect of royalties and fees for technical services in the country where the same arises. Para 4 of the Protocol to the said Agreement reads as below:-- "With reference to paragraph 2 of article 13, in t .....

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..... ubsequent to the signing of the Agreement with Canada, India has entered into Agreements with other OECD countries, wherein the rate of taxation in respect of royalties and fees for technical services has been agreed at 20% of the gross amount. The revised Agreement with Swedan, which came into force on 12th December, 1988 (See [1989] 178 ITR (St.) 13), is the first of such Agreements. Accordingly .....

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