https://www.taxtmi.com/acts?id=5606 Royalties and fees for technical services arising in a Contracting State may be taxed in the recipient's State and also in the source State subject to a limited withholding where the recipient is the beneficial owner. The Article defines royalties and fees for technical services, excludes services covered by other Articles, limits the withholding where the beneficial owner is not effectively connected to a permanent establishment or fixed base in the source State, deems source where the payer or relevant permanent establishment is located, and treats payments exceeding arm's length amounts as taxable only to the arm's length portion under this Article. en-us Sat, 19 Jan 2008 22:45:54 +0530 Tue, 19 Nov 2024 14:12:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5606 Royalties and fees for technical services arising in a Contracting State may be taxed in the recipient's State and also in the source State subject to a limited withholding where the recipient is the beneficial owner. The Article defines royalties and fees for technical services, excludes services covered by other Articles, limits the withholding where the beneficial owner is not effectively connected to a permanent establishment or fixed base in the source State, deems source where the payer or relevant permanent establishment is located, and treats payments exceeding arm's length amounts as taxable only to the arm's length portion under this Article. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5606