https://www.taxtmi.com/acts?id=5241 Article 12 permits taxation of royalties and fees for technical services by the State of residence and by the State where such payments arise; where the recipient is the beneficial owner a reduced withholding applies. It defines royalties to include payments for use of intellectual property and equipment, and fees for technical services to include managerial, technical or consultancy services (excluding certain other Articles). Income effectively connected to a permanent establishment or fixed base is taxed under Articles 7 or 14, and special relationship rules limit taxation to arm's length amounts, leaving excess taxable under domestic law. en-us Sat, 19 Jan 2008 22:45:54 +0530 Tue, 26 Nov 2024 15:05:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5241 Article 12 permits taxation of royalties and fees for technical services by the State of residence and by the State where such payments arise; where the recipient is the beneficial owner a reduced withholding applies. It defines royalties to include payments for use of intellectual property and equipment, and fees for technical services to include managerial, technical or consultancy services (excluding certain other Articles). Income effectively connected to a permanent establishment or fixed base is taxed under Articles 7 or 14, and special relationship rules limit taxation to arm's length amounts, leaving excess taxable under domestic law. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5241