Taxation of royalties and technical service fees: source and residence rules with limits and permanent establishment interaction.

The DTAA allocates taxation of cross border royalties and fees for technical services between source and residence States, permits source State taxation subject to a limit where the recipient is beneficial owner, defines royalties and technical service fees broadly, excludes payments effectively connected with a permanent establishment or fixed base from these rules, and applies deemed source and related party arm's length adjustment provisions.

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