https://www.taxtmi.com/acts?id=4683 Article 13 permits source state taxation of royalties, fees for technical services and payments for use of equipment paid to residents of the other Contracting State, with a reduced withholding when the recipient is the beneficial owner. It defines royalties, technical service fees and equipment payments, excludes payments attributable to employment or specified independent services, and disapplies the Article where the income is effectively connected with a permanent establishment or fixed base. Special relationships that inflate payments are limited to arm's length amounts. en-us Sat, 19 Jan 2008 22:45:54 +0530 Tue, 19 Nov 2024 16:45:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4683 Article 13 permits source state taxation of royalties, fees for technical services and payments for use of equipment paid to residents of the other Contracting State, with a reduced withholding when the recipient is the beneficial owner. It defines royalties, technical service fees and equipment payments, excludes payments attributable to employment or specified independent services, and disapplies the Article where the income is effectively connected with a permanent establishment or fixed base. Special relationships that inflate payments are limited to arm's length amounts. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4683