https://www.taxtmi.com/acts?id=4763 Royalties and fees for technical services paid to a resident of the other Contracting State may be taxed in both the residence and source States; where the recipient is the beneficial owner, source taxation is permitted subject to a reduced withholding ceiling. Royalties include payments for use of rights in copyrights, patents, trademarks, designs, plans, secret formulas, processes, equipment and related information. Fees for technical services cover managerial, technical or consultancy services including personnel, excluding Articles 14 and 15 services. If the beneficial owner has a permanent establishment or fixed base in the source State and the payments are effectively connected, Articles 7 or 14 apply. Special-relationship adjustments limit application to the arm's length amount. en-us Sat, 19 Jan 2008 22:45:54 +0530 Wed, 20 Nov 2024 17:42:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4763 Royalties and fees for technical services paid to a resident of the other Contracting State may be taxed in both the residence and source States; where the recipient is the beneficial owner, source taxation is permitted subject to a reduced withholding ceiling. Royalties include payments for use of rights in copyrights, patents, trademarks, designs, plans, secret formulas, processes, equipment and related information. Fees for technical services cover managerial, technical or consultancy services including personnel, excluding Articles 14 and 15 services. If the beneficial owner has a permanent establishment or fixed base in the source State and the payments are effectively connected, Articles 7 or 14 apply. Special-relationship adjustments limit application to the arm's length amount. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4763