https://www.taxtmi.com/acts?id=5124 Fees for technical services arising in a Contracting State may be taxed in the State where they arise, but if the recipient is the beneficial owner the tax charged in that State shall not exceed 10 per cent of the gross amount. The term covers managerial, technical or consultancy services including provision of personnel, excluding services covered by other Articles. If the beneficial owner has a permanent establishment or fixed base in the source State and the fees are effectively connected with it, business profits or independent services provisions apply. Special-relationship pricing adjustments limit treaty application to the arm's-length amount. en-us Sat, 19 Jan 2008 22:45:54 +0530 Sat, 07 Mar 2009 09:53:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5124 Fees for technical services arising in a Contracting State may be taxed in the State where they arise, but if the recipient is the beneficial owner the tax charged in that State shall not exceed 10 per cent of the gross amount. The term covers managerial, technical or consultancy services including provision of personnel, excluding services covered by other Articles. If the beneficial owner has a permanent establishment or fixed base in the source State and the fees are effectively connected with it, business profits or independent services provisions apply. Special-relationship pricing adjustments limit treaty application to the arm's-length amount. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5124