| |
| | Tax Planning International Review - India/United States (Site not responding. Last check: 2007-09-10) |
 | | Hindalco Industries Limited, an Indian company, entered into an agreement with Reynolds International Inc. (RII), USA, for the acquisition of know-how, process technology and technical assistance to enable Hindalco and its consultants to design, construct and operate a plant to manufacture aluminum foil. |
 | | Hindalco also concluded a technical assistance agreement with Reynolds (Europe) Limited (REL), USA, under which it paid USD 50,000 each quarter as technical service fees and USD 12,500 each quarter as basic fees for the training of Hindalco's employees at REL's facilities or the facilities of REL's affiliates outside India. |
 | | Hindalco also referred to other articles in the treaty that use the term "physical property" to support the proposition that "property" is broader than "physical property", and that "property" should encompass intangibles such as know-how, which would then fall under the exclusion in Article 12(5)(a). |
| subscript.bna.com /samples/tpr.nsf/125731d8816a84d385256297005f336a/167f8219cf673a4c852570c9006af028?OpenDocument (1316 words) |
|