https://www.taxtmi.com/acts?id=4477 Article 12 permits taxation of royalties and fees for included services in the recipient's State, while allowing the source State to tax them subject to specified maximum withholding rates for different categories and transitional periods. The Article defines royalties and fees for included services, excludes specified service types from the fees definition, provides deeming rules on source and permanent establishment linkage, and limits source taxation where payments exceed arm's length amounts between related parties. en-us Sat, 19 Jan 2008 22:45:54 +0530 Thu, 07 Nov 2024 18:23:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4477 Article 12 permits taxation of royalties and fees for included services in the recipient's State, while allowing the source State to tax them subject to specified maximum withholding rates for different categories and transitional periods. The Article defines royalties and fees for included services, excludes specified service types from the fees definition, provides deeming rules on source and permanent establishment linkage, and limits source taxation where payments exceed arm's length amounts between related parties. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4477