https://www.taxtmi.com/acts?id=6164 Taxation of cross-border royalties and fees for technical services permits residence-state taxation of recipients while allowing source-state taxation where payments arise, subject to treaty withholding ceilings that vary by payment category and transitional phase. Definitions distinguish royalties (payments for use or right to use intellectual property or equipment) and fees for technical services (ancillary services, provision of technical personnel, transfer of know how), with specific exclusions. Payments are sourced to the payer's State or to the State of a relevant permanent establishment or fixed base, and special relationship, permanent establishment and main purpose rules limit treaty relief. en-us Sat, 19 Jan 2008 22:45:54 +0530 Tue, 08 Oct 2024 10:29:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=6164 Taxation of cross-border royalties and fees for technical services permits residence-state taxation of recipients while allowing source-state taxation where payments arise, subject to treaty withholding ceilings that vary by payment category and transitional phase. Definitions distinguish royalties (payments for use or right to use intellectual property or equipment) and fees for technical services (ancillary services, provision of technical personnel, transfer of know how), with specific exclusions. Payments are sourced to the payer's State or to the State of a relevant permanent establishment or fixed base, and special relationship, permanent establishment and main purpose rules limit treaty relief. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=6164