Royalty rate under Spain DTAA notified

The notification holds importance especially in view of the recent Supreme Court judgement in the case of Nestle wherein it was held that the Most favoured Nation clause is not auto-executory. “The notification ensures availability of the benefit of lower Tax Rate with respect to Royalty income & FTS under the India Spain Tax Treaty,” Pranav Sayta, Partner & Leader International Tax and Transaction Services, EY India said.