https://www.taxtmi.com/acts?id=4507 paid to a resident of the other Contracting State may be taxed in the recipient's State of residence and in the source State; where the recipient is the beneficial owner the source State's tax on such payments shall not exceed 10 per cent of the gross amount. "Royalties" includes payments for use of copyrights, patents, trademarks, designs, plans, secret formulas, processes, equipment or information; "fees for technical services" means payments for managerial, technical or consultancy services, excluding certain activities. If the beneficial owner has a permanent establishment or fixed base in the source State and the payment is effectively connected with it, provisions on business profits or independent personal services apply. Special-relationship adjustments limit treaty application to arm's-length amounts. en-us Sat, 19 Jan 2008 22:45:54 +0530 Fri, 08 Nov 2024 16:05:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4507 paid to a resident of the other Contracting State may be taxed in the recipient's State of residence and in the source State; where the recipient is the beneficial owner the source State's tax on such payments shall not exceed 10 per cent of the gross amount. "Royalties" includes payments for use of copyrights, patents, trademarks, designs, plans, secret formulas, processes, equipment or information; "fees for technical services" means payments for managerial, technical or consultancy services, excluding certain activities. If the beneficial owner has a permanent establishment or fixed base in the source State and the payment is effectively connected with it, provisions on business profits or independent personal services apply. Special-relationship adjustments limit treaty application to arm's-length amounts. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4507