https://www.taxtmi.com/acts?id=5424 Article 14 permits source-State taxation of technical fees arising in a Contracting State but limits the source-State withholding where the recipient is the beneficial owner to the substituted notified rate; it defines technical fees as payments for technical, managerial or consultancy services (other than to employees). The Article excludes this regime when fees are effectively connected to a permanent establishment or fixed base, directs application of Article 7 or 16 in that case, deems source based on the payer or PE/fixed base bearing the liability, and requires arm's-length adjustment where special relationships inflate payment amounts. en-us Sat, 19 Jan 2008 22:45:54 +0530 Thu, 26 Jun 2025 11:51:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5424 Article 14 permits source-State taxation of technical fees arising in a Contracting State but limits the source-State withholding where the recipient is the beneficial owner to the substituted notified rate; it defines technical fees as payments for technical, managerial or consultancy services (other than to employees). The Article excludes this regime when fees are effectively connected to a permanent establishment or fixed base, directs application of Article 7 or 16 in that case, deems source based on the payer or PE/fixed base bearing the liability, and requires 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=5424