https://www.taxtmi.com/acts?id=6146 Royalties and fees for technical services arising in one Contracting State may be taxed in that State, but if paid to the beneficial owner residing in the other State the source State's tax is capped. "Royalties" covers payments for rights to use copyrights, patents, trademarks, designs, plans, formulas, processes, equipment or technical information; "fees for technical services" covers managerial, technical or consultancy services including personnel services. If the beneficial owner has a permanent establishment or fixed base in the source State and the rights are effectively connected there, rules on business profits or independent personal services apply instead. en-us Sat, 19 Jan 2008 22:45:54 +0530 Thu, 21 Nov 2024 16:47:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=6146 Royalties and fees for technical services arising in one Contracting State may be taxed in that State, but if paid to the beneficial owner residing in the other State the source State's tax is capped. "Royalties" covers payments for rights to use copyrights, patents, trademarks, designs, plans, formulas, processes, equipment or technical information; "fees for technical services" covers managerial, technical or consultancy services including personnel services. If the beneficial owner has a permanent establishment or fixed base in the source State and the rights are effectively connected there, rules on business profits or independent personal services apply instead. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=6146