https://www.taxtmi.com/acts?id=4793 Royalties and fees for technical services arising in one Contracting State may be taxed in the source State but, where the recipient is the beneficial owner, source tax is limited; definitions set royalties to include payments for use of intellectual property, transmissions and technical information, and fees for technical services to include managerial, technical or consultancy services. The source taxation rules do not apply if the beneficial owner has a permanent establishment or fixed base in the source State and the payments are effectively connected with that presence; special-relationship provisions require arm's-length adjustments, with excess taxable under domestic law. en-us Sat, 19 Jan 2008 22:45:54 +0530 Thu, 21 Nov 2024 12:43:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4793 Royalties and fees for technical services arising in one Contracting State may be taxed in the source State but, where the recipient is the beneficial owner, source tax is limited; definitions set royalties to include payments for use of intellectual property, transmissions and technical information, and fees for technical services to include managerial, technical or consultancy services. The source taxation rules do not apply if the beneficial owner has a permanent establishment or fixed base in the source State and the payments are effectively connected with that presence; special-relationship provisions require arm's-length adjustments, with excess taxable under domestic law. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4793