https://www.taxtmi.com/acts?id=5816 Royalties and fees for technical services arising in one Contracting State may be taxed in the recipient's State, and may also be taxed in the source State but, if the beneficial owner is resident in the other State, source taxation is limited to a reduced maximum withholding rate. Exceptions apply where the beneficial owner has a permanent establishment or fixed base in the source State and the right or property is effectively connected, in which case rules on business profits or independent personal services govern. Payments deemed to arise where the payer or attributable permanent establishment/fixed base is situated. Special relationships require arm's length adjustment. en-us Sat, 19 Jan 2008 22:45:54 +0530 Wed, 27 Nov 2024 13:13:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5816 Royalties and fees for technical services arising in one Contracting State may be taxed in the recipient's State, and may also be taxed in the source State but, if the beneficial owner is resident in the other State, source taxation is limited to a reduced maximum withholding rate. Exceptions apply where the beneficial owner has a permanent establishment or fixed base in the source State and the right or property is effectively connected, in which case rules on business profits or independent personal services govern. Payments deemed to arise where the payer or attributable permanent establishment/fixed base is situated. Special relationships require arm's length adjustment. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5816