Advance ruling on tax rate applicable to royalty income derived by a Japanese company in India

The income by way of royalty accruing to the Japanese company is liable to be taxed in terms of Article 12 of the DTAA between India and Japan at a rate not exceeding 10 per cent from the assessment year 2008-09 onwards. RELEVANT PARAGRAPH 1. The applicant is a company incorporated in Japan. It is engaged in construction activities and provides architectural and civil engineering services. SMCC Construction India Limited (SMCI) is an Indian Company and a subsidiary of the applicant and is operating as a construction company involved in general construction and civil engineering. The said Compa...