Taxation of Copyright Royalties in India - Interplay of Copyright Law and Income Tax
Bibliographic record
Abstract
The book is a thematic commentary on the law relating to taxation of royalty payments in respect of copyright both under the Income-tax Act, 1961 and tax treaties. The book deals with payments for transfer of rights in respect of copyright and for the use of copyright, to give a sharply focussed view on the subject. The book dives deep into the various facets of copyright law as well as analyses the differences in copyright laws of various countries and their impact on income taxation. The book discusses the rich jurisprudence from the United States, the United Kingdom, Poland, Canada, and other countries and examines their relevance for taxation. The commentary first explores the concepts of nature of copyright; the varying consequences of ownership, licence, and assignment of copyrighted works; copyright royalty under tax laws and treaties before delving into the specific scenarios that arise in case of software, cinematographic films, broadcasts, and databases. The author has also addressed questions of law owing to digitisation and the internet. The controversies surrounding characterisation of software payments made by the end users and the resellers are analysed. The book analyses the changes made to the OECD Model Convention Commentary on Article 12 on Royalties in respect of software payments. Published by Oakbridge Publishing P Ltd (2019).
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How this classification was reachedexpand
Full frame distilled prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. Learned from the 10,348 direct Codex labels and 10,348 direct Gemma labels. Candidate is the union of thresholded teacher heads; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels or direct frontier model labels.
Codex and Gemma teacher scores by category
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.001 | 0.000 |
| Meta-epidemiology (narrow) | 0.000 | 0.000 |
| Meta-epidemiology (broad) | 0.000 | 0.000 |
| Bibliometrics | 0.000 | 0.000 |
| Science and technology studies | 0.000 | 0.000 |
| Scholarly communication | 0.000 | 0.001 |
| Open science | 0.000 | 0.000 |
| Research integrity | 0.000 | 0.001 |
| Insufficient payload (model declined to judge) | 0.001 | 0.000 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; a candidate call from one teacher head, not a consensus.
How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".