https://www.taxtmi.com/acts?id=4851 Article 12 permits taxing of royalties and fees for technical services in the recipient's residence State and also in the source State, subject to a tax ceiling where the recipient is the beneficial owner. The Article defines royalties and fees for technical services, excludes payments effectively connected with a permanent establishment or fixed base (where other Articles apply), attributes source to the payer or the payer's permanent establishment when liable, and requires arm's-length adjustment where special relationships inflate payments. en-us Sat, 19 Jan 2008 22:45:54 +0530 Wed, 04 Dec 2024 17:11:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4851 Article 12 permits taxing of royalties and fees for technical services in the recipient's residence State and also in the source State, subject to a tax ceiling where the recipient is the beneficial owner. The Article defines royalties and fees for technical services, excludes payments effectively connected with a permanent establishment or fixed base (where other Articles apply), attributes source to the payer or the payer's permanent establishment when liable, and requires arm's-length adjustment where special relationships inflate payments. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4851