https://www.taxtmi.com/acts?id=5153 Taxation of technical fees permits taxation in both the recipient's residence and the source State, but source state tax on payments to the beneficial owner is capped. Technical fees mean payments (other than to an employee) for technical, managerial or consultancy services. Where the beneficial owner has a permanent establishment in the source State or performs independent personal services there and the fees are effectively connected, rules for business profits or independent services apply. Technical fees arise where the payer is the State or a resident, or where borne by a permanent establishment, and related party excesses are limited to arm's length amounts. en-us Sat, 19 Jan 2008 22:45:54 +0530 Sat, 07 Mar 2009 09:54:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5153 Taxation of technical fees permits taxation in both the recipient's residence and the source State, but source state tax on payments to the beneficial owner is capped. Technical fees mean payments (other than to an employee) for technical, managerial or consultancy services. Where the beneficial owner has a permanent establishment in the source State or performs independent personal services there and the fees are effectively connected, rules for business profits or independent services apply. Technical fees arise where the payer is the State or a resident, or where borne by a permanent establishment, and related party excesses are limited to arm's length amounts. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5153