The Ministry of Finance (MoF) on March 19, 2024, issued the modifications to the conventions which are necessary for implementing the said Convention between India and Spain
The following has been stated namely: -
• In the Convention annexed therewith between the Republic of India and the Kingdom of Spain, in Article 13 relating to Royalties and Fees for Technical Services, for paragraph 2, the following paragraph shall be substituted, namely:
“2. However, such royalties and fees for technical services may also be taxed in the Contracting State in which they arise and according to the law of that State, but if the recipient is the beneficial owner of the royalties or fees for technical services, the tax so charged shall not exceed ten percent of the gross amount of royalties or fees for technical services.”.
The paragraph shall be applicable with effect from the assessment year 2024-25.
[Notification No. S.O. 1484(E)]
