https://www.taxtmi.com/acts?id=5939 Management or professional fees arising in a Contracting State may be taxed in the recipient's State, while the source State may tax them subject to a treaty limit; fees mean payments (other than to employees) for managerial, technical or consultancy services. If the recipient has a permanent establishment or fixed base in the source State and the fees are effectively connected with it, provisions for business profits or independent personal services apply. Fees are deemed to arise where paid by the State, its subdivisions or a resident, or where a payer's permanent establishment incurred and bore the liability. Excess payments above arm's-length are excluded from this Article. en-us Sat, 19 Jan 2008 22:45:54 +0530 Sat, 07 Mar 2009 11:33:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5939 Management or professional fees arising in a Contracting State may be taxed in the recipient's State, while the source State may tax them subject to a treaty limit; fees mean payments (other than to employees) for managerial, technical or consultancy services. If the recipient has a permanent establishment or fixed base in the source State and the fees are effectively connected with it, provisions for business profits or independent personal services apply. Fees are deemed to arise where paid by the State, its subdivisions or a resident, or where a payer's permanent establishment incurred and bore the liability. Excess payments above arm's-length are excluded from this Article. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5939