https://www.taxtmi.com/acts?id=5635 Royalties paid to a resident of the other Contracting State may be taxed in that other State, while the source State may also tax such royalties subject to a withholding cap when the recipient is the beneficial owner; permanent establishment or fixed base connections supplant the withholding rule and arm's length adjustment limits the Article's application where special relationships inflate payments. en-us Sat, 19 Jan 2008 22:45:54 +0530 Fri, 22 Nov 2024 10:31:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5635 Royalties paid to a resident of the other Contracting State may be taxed in that other State, while the source State may also tax such royalties subject to a withholding cap when the recipient is the beneficial owner; permanent establishment or fixed base connections supplant the withholding rule and arm's length adjustment limits the Article's application where special relationships inflate payments. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5635