DTAA provisions - TDS rate for vessel inspection services (i.e, technical services) - $ remittance to UAE supplier

[SOPL SOPL]

Dear Sir/Madam,

we need to make $ payment to UAE (Supplier) for vessel inspection services. Since it was services, we are liable for TDS deduction U/s.195. (in my view , it will come under fee for technical services)

After reading the DTAA provisions of UAE, fees for technical services ( article-12) is having no content or no seperate provision. It seems that TDS is not applicable for technical services on payment to UAE.

My queries ;

1. Is my understanding is correct regarding - No, TDS on fees payment to UAE on technical services

2. is it comes under any other nature of service for TDS applicability ? So, please mention the relevant article along with TDS rate

Thanking you..,

AI Summary

Withholding tax on cross-border technical services: query whether TDS applies to foreign vessel inspection fees under DTAA and domestic law
Query whether withholding under domestic law applies to cross border payments for vessel inspection services treated as technical services; the payer notes the DTAA provision for fees for technical services (Article 12) appears to lack an operative rule and asks if DTAA relief applies or whether the payment should be characterised under another treaty or domestic service category to determine the applicable treaty article and withholding consequence.