https://www.taxtmi.com/acts?id=5996 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 may also be taxed in the State of source; if the recipient is the beneficial owner the source tax is limited by a cap. The Article defines royalties to include payments for copyrights, patents, know how, software and technical information, and defines fees for technical services to include managerial, technical or consultancy services. Payments effectively connected with a permanent establishment or fixed base are taxed under the provisions governing that establishment, and related party excess amounts are limited to arm's length consideration. en-us Sat, 19 Jan 2008 22:45:54 +0530 Mon, 02 Dec 2024 14:50:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5996 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 may also be taxed in the State of source; if the recipient is the beneficial owner the source tax is limited by a cap. The Article defines royalties to include payments for copyrights, patents, know how, software and technical information, and defines fees for technical services to include managerial, technical or consultancy services. Payments effectively connected with a permanent establishment or fixed base are taxed under the provisions governing that establishment, and related party excess amounts are limited to arm's length consideration. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5996