https://www.taxtmi.com/acts?id=5330 Article 12 permits both source and resident States to tax royalties and fees for technical services paid to a resident of the other State, but where the recipient is the beneficial owner the source State's tax is limited by a withholding cap and the competent authorities shall agree the mode of its application. The Article defines royalties and fees for technical services, enumerates exclusions, treats payments connected to a permanent establishment or fixed base as taxable under business profits or independent personal services provisions, and requires arm's length adjustment where related party relationships distort amounts. en-us Sat, 19 Jan 2008 22:45:54 +0530 Mon, 16 Dec 2024 15:41:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5330 Article 12 permits both source and resident States to tax royalties and fees for technical services paid to a resident of the other State, but where the recipient is the beneficial owner the source State's tax is limited by a withholding cap and the competent authorities shall agree the mode of its application. The Article defines royalties and fees for technical services, enumerates exclusions, treats payments connected to a permanent establishment or fixed base as taxable under business profits or independent personal services provisions, and requires arm's length adjustment where related party relationships distort amounts. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5330