UK HMRC has published an updated version of the synthesized text of the 1993 tax treaty with India as impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The update, dated 12 October 2022, includes the addition of Section(2)(bb)(ii) in Article 13 (Royalties and Fees for Technical Services), which is an original provision of the treaty but was excluded in the prior version of the synthesized text. Under the treaty, a 20% withholding tax rate generally applied for the first 5 years on royalties paid for the use of or right to use a copyright, patent, or trademark, as well as certain technical services, although a 15% rate applied if the payer was the government of a Contacting State. After 5 years, Section(2)(bb)(ii) provides that the rate is 15% in general.

Click the following link for the updated synthesized text of the 1993 UK-India tax treaty.