https://www.taxtmi.com/acts?id=4387 Royalties and fees for technical services arising in one Contracting State and paid to a resident of the other State may be taxed in the recipient's State of residence, while the source State may also tax such payments subject to a cap when the beneficial owner is resident elsewhere. The Article defines royalties to include payments for use of intellectual property and related information, and fees for technical services to include managerial, technical or consultancy services. Payments connected with a permanent establishment or fixed base are governed by Article 7 or Article 14, and amounts exceeding an arm's-length value due to special relationships remain taxable under domestic law. en-us Sat, 19 Jan 2008 22:45:54 +0530 Wed, 06 Nov 2024 14:19:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4387 Royalties and fees for technical services arising in one Contracting State and paid to a resident of the other State may be taxed in the recipient's State of residence, while the source State may also tax such payments subject to a cap when the beneficial owner is resident elsewhere. The Article defines royalties to include payments for use of intellectual property and related information, and fees for technical services to include managerial, technical or consultancy services. Payments connected with a permanent establishment or fixed base are governed by Article 7 or Article 14, and amounts exceeding an arm's-length value due to special relationships remain taxable under domestic law. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4387