https://www.taxtmi.com/acts?id=5152 Article 12 permits the source State to tax royalties and fees for included services paid to a resident of the other Contracting State but limits source taxation where the recipient is the beneficial owner. It defines royalties and fees for included services by reference to use of intellectual property, equipment, supplied technical knowledge, and technical or consultancy services; deems payments to arise where the payer or connected permanent establishment or fixed base is situated; and applies an arm's length adjustment where special relationships inflate payment amounts. en-us Sat, 19 Jan 2008 22:45:54 +0530 Fri, 06 Mar 2009 16:59:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5152 Article 12 permits the source State to tax royalties and fees for included services paid to a resident of the other Contracting State but limits source taxation where the recipient is the beneficial owner. It defines royalties and fees for included services by reference to use of intellectual property, equipment, supplied technical knowledge, and technical or consultancy services; deems payments to arise where the payer or connected permanent establishment or fixed base is situated; and applies an arm's length adjustment where special relationships inflate payment amounts. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5152