https://www.taxtmi.com/acts?id=5067 Royalties and fees for technical services arising in one Contracting State and paid to a resident of the other may be taxed in the recipient's State, while the source State may also tax them subject to a capped rate when the recipient is the beneficial owner. The Article defines royalties and fees for technical services, excludes certain services covered elsewhere, treats income as arising where the payer or a related permanent establishment is situated, displaces source taxation when income is effectively connected with a permanent establishment or fixed base, and permits adjustments where related party relationships inflate amounts. en-us Sat, 19 Jan 2008 22:45:54 +0530 Mon, 25 Nov 2024 16:54:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5067 Royalties and fees for technical services arising in one Contracting State and paid to a resident of the other may be taxed in the recipient's State, while the source State may also tax them subject to a capped rate when the recipient is the beneficial owner. The Article defines royalties and fees for technical services, excludes certain services covered elsewhere, treats income as arising where the payer or a related permanent establishment is situated, displaces source taxation when income is effectively connected with a permanent establishment or fixed base, and permits adjustments where related party relationships inflate amounts. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5067