https://www.taxtmi.com/acts?id=5755 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, but the source State may also tax them; where the recipient is the beneficial owner the tax so charged shall not exceed ten per cent of the gross amount. Payments connected with a permanent establishment or fixed base in the source State are governed by Article 7 or Article 15. Related party excess payments are limited to arm's length amounts under this Article. en-us Sat, 19 Jan 2008 22:45:54 +0530 Tue, 26 Nov 2024 15:34:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5755 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, but the source State may also tax them; where the recipient is the beneficial owner the tax so charged shall not exceed ten per cent of the gross amount. Payments connected with a permanent establishment or fixed base in the source State are governed by Article 7 or Article 15. Related party excess payments are limited to arm's length amounts under this Article. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5755