https://www.taxtmi.com/acts?id=4224 Article 12 allows taxation of royalties and fees for technical services in the recipient's State and also permits source-state taxation with a limited withholding charge where the beneficial owner is a resident of the other Contracting State. It defines royalties (including payments for use of copyrights, patents, trademarks, designs, plans, secret formulas, equipment and technical information) and fees for technical services (managerial, technical or consultancy services, including personnel). Income connected with a permanent establishment or fixed base is taxed under the provisions applicable to business profits or independent personal services, and payments exceeding arm's length due to special relationships are restricted to the arm's length amount under the Article. en-us Sat, 19 Jan 2008 22:45:54 +0530 Mon, 04 Nov 2024 14:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4224 Article 12 allows taxation of royalties and fees for technical services in the recipient's State and also permits source-state taxation with a limited withholding charge where the beneficial owner is a resident of the other Contracting State. It defines royalties (including payments for use of copyrights, patents, trademarks, designs, plans, secret formulas, equipment and technical information) and fees for technical services (managerial, technical or consultancy services, including personnel). Income connected with a permanent establishment or fixed base is taxed under the provisions applicable to business profits or independent personal services, and payments exceeding arm's length due to special relationships are restricted to the arm's length amount under the Article. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4224