Rate of tax on Royalty / License fee - 10% u/s 115A or higher ...

Debate on 10% vs. 15% Tax Rate for Royalties u/s 115A and UK DTAA Agreement.

December 4, 2014

Case Laws Income Tax AT

Rate of tax on Royalty / License fee - 10% u/s 115A or higher rate @ 15% as per DTAA with United Kingdom - The provisions of section 115A(1)(b)(AA) does not debar the assessee to enter into new agreements after change of situation - AT

View Source

← Previous Next →

Rate of tax on Royalty / License fee - 10% u/s 115A or higher ...

Debate on 10% vs. 15% Tax Rate for Royalties u/s 115A and UK DTAA Agreement.

December 4, 2014

Case Laws Income Tax AT

You may also like:

Rate of tax to be applied on the royalty received under the royalty agreement - Under section 115A of the Act, it is provided that in case any new royalty agreement is...

Levy of tax on the royalties or fees for technical services - rate of tax under the DTAA - 12% or 10% - the substitution has the effect of deleting the old rule and...

Application of section 115A or DTAA separately for one sources of income covered by different agreements - From perusal of the aforesaid explanatory notes, it is evident...

Levy of Surcharge and cess - to be computed over the rate of tax as per DTAA or not - Article 12 read with Article 2 of the tax treaty makes it clear that the rate of...

Income accrued in India - royalty receipts - transfer of copyright in the software - India-UK DTAA - The Impugned Rulings passed by the learned AAR are set aside and it...

Royalty income from franchisee hotels - there is no agreement in terms of which the assessee was paid royalty is legally and factually correct, and therefore, the...

The Income Tax Appellate Tribunal (ITAT) held that the assessee is entitled to the concessional tax rate of 10% on royalty income u/s 115BBF, as the assessee had...

Non-resident individual seconded on overseas assignment to UK - Salary received for employment exercised in UK taxable only in UK under Article 15(1) of India-UK DTAA,...

Clubbing of income of Non-resident and Permanent Establishment (PE) - Levy of surcharge at 5% as against assessee’s claim of 2% - The royalty and Fee for Technical...

FTS in the given case would be taxed at the beneficial rate of 15% on gross receipts as provided in Article 13(2) of the India-UK DTAA. - the tax liability borne by GRSE...

Co-operative Societies - Rate of Income Tax - For normal provision same rate of tax and surcharge as applicable will continue and for computation of tax under sec 115BAD...

Levy of surcharge and education over 10% tax as per the DTAA between India and France on royalty - revenue cannot levy surcharge and education cess, which is also in the...

Levy of Dividend distribution tax (DDT) at the rate of 20.36% u/s 115O - claim of assessee that it should have been levied at the rate of 15% in terms of Article 10 of...

Foreign tax credit claimed under Article 24 of India- UK DTAA read with Section 90 - assessee who is a resident of India and has derived from salary which has suffered...

The assessee, a US citizen residing permanently in India, claimed that the tax rates specified in the India-USA DTAA include surcharge, surtax, and education cess would...

Quick Updates: