Double Taxation Agreement

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ROYALTIES
ARTICLE 12

68	Scope.
69.	Taxability in the source country.
69.1	Inter-relationship between the taxation by the countries of source and recipient.
70.	Arising or deemed arising in a country.
70.1	Royalty.
70.2	Fees for technical services.
71.	Royalty.
71.1	Royalty generally defined.
71.1-1	Royalty from mine, quarry, etc., to be taxed as income form immovable property or as business.
71.2	Royalties as defined in double taxation agreements.
71.3	Royalty as defined under the Indian Income-tax Ordinance, 1979 .
71.3-1	Whether receipt of technical fee could be taxed on the basis of its arising because of business connection, or as royalty.
71.4	Royalty as defined in the Model Convention.
71.4-1	Receipt of consideration for the use or right to use of technical knowledge.
71.4-2	Industrial properties and technical know-how- Transfer of revenue receipt or capital gains.
71.5	Specialised knowledge or service yields royalty.
71.6	Copyright.
71.7	Patent.
71.8	Design.
71.9	Trade mark.
71.10	Model.
71.11	Technical know-how and information concerning industrial, commercial and scientific experience.
71.12	Technical know-how.
71.13	Equipment, use of or sale of, distinction.
71.13-1	Franchising.
71.13-2	Licensing.
71.13-3	Turnkey plants.
71.13-4	Co-production agreements.
71.13-5	Joint ventures.
72.	Article 12 vis-a-vis Article 11.