https://www.taxtmi.com/acts?id=4537 Technical fees are payments to non-employees for technical, managerial or consultancy services; while taxable in the resident State, the source State may also tax them but, if the recipient is the beneficial owner, withholding on the gross amount is capped at ten percent. Exceptions apply where fees are effectively connected with a permanent establishment or independent personal services in the source State, in which case business profits or personal services rules govern. Sourcing includes payments by the State or a resident, and related-party excesses are limited to arm's-length amounts for treaty treatment. en-us Sat, 19 Jan 2008 22:45:54 +0530 Fri, 06 Mar 2009 18:12:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4537 Technical fees are payments to non-employees for technical, managerial or consultancy services; while taxable in the resident State, the source State may also tax them but, if the recipient is the beneficial owner, withholding on the gross amount is capped at ten percent. Exceptions apply where fees are effectively connected with a permanent establishment or independent personal services in the source State, in which case business profits or personal services rules govern. Sourcing includes payments by the State or a resident, and related-party excesses are limited to arm's-length amounts for treaty treatment. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4537