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of <h1>Article 12A of UN Model Tax Convention: Taxation of Technical Service Fees in Contracting States with Negotiated Tax Rate Caps.</h1> Article 12A of the UN Model Tax Convention addresses the taxation of fees for technical services, allowing such fees paid to a resident of one Contracting State by another to be taxed in both states, with a cap on the tax rate determined through bilateral negotiations. Exceptions apply if the fees are connected to a permanent establishment or fixed base. Fees are deemed to arise in a state if the payer is a resident or has a permanent establishment there. Special relationships affecting fee amounts are taxed according to each state's laws. The term excludes payments to employees, educational services, or personal use services. Indian law has specific provisions for such fees since 1976.
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