https://www.taxtmi.com/acts?id=4653 Article 13 permits source state taxation of royalties and fees for technical services subject to specified withholding caps and categories; it defines royalties to include payments for rights and use of intellectual property and equipment, and fees for technical services to include ancillary consultancy, provision of technical personnel, know how transfer and technical design, while excluding services tied to sales, international transport rentals, teaching, private use, and employment; payments effectively connected to a permanent establishment or fixed base fall under business profits or independent personal services rules, and related party excesses are limited to arm's length amounts. en-us Sat, 19 Jan 2008 22:45:54 +0530 Fri, 06 Mar 2009 18:16:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4653 Article 13 permits source state taxation of royalties and fees for technical services subject to specified withholding caps and categories; it defines royalties to include payments for rights and use of intellectual property and equipment, and fees for technical services to include ancillary consultancy, provision of technical personnel, know how transfer and technical design, while excluding services tied to sales, international transport rentals, teaching, private use, and employment; payments effectively connected to a permanent establishment or fixed base fall under business profits or independent personal services rules, and related party excesses are limited to arm's length amounts. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4653