https://www.taxtmi.com/acts?id=5664 Royalties and fees for technical services arising in one Contracting State and paid to a resident of the other may be taxed in the recipient's State; the source State may also tax them but source tax on such payments to the beneficial owner is limited. The Article defines royalties and fees for technical services, lists specific exclusions, provides that effective connection with a permanent establishment or fixed base shifts taxation to Articles 7 or 14, and requires arm's length adjustment where related party arrangements inflate payments. en-us Sat, 19 Jan 2008 22:45:54 +0530 Sat, 23 Nov 2024 11:13:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5664 Royalties and fees for technical services arising in one Contracting State and paid to a resident of the other may be taxed in the recipient's State; the source State may also tax them but source tax on such payments to the beneficial owner is limited. The Article defines royalties and fees for technical services, lists specific exclusions, provides that effective connection with a permanent establishment or fixed base shifts taxation to Articles 7 or 14, and requires arm's length adjustment where related party arrangements inflate payments. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5664