Taxation of Royalties, Fees for Technical Service, Dividends and Interest

This article presents a detailed and critical analysis of taxation of passive income in the hands of non-residents. While elaborating the scope and application of relevant provisions and case law, the article specifically highlights the areas of conflict in taxing such receipts, specifically characterization of income, implications in the presence or absence of a permanent establishment, taxation on net or gross basis, applicable tax rates, etc.