https://www.taxtmi.com/acts?id=6194 Source-state may tax royalties and fees for technical services paid to a nonresident, but where the recipient is the beneficial owner a ceiling limits the source tax. "Royalties" is defined to include payments for use or right to use intellectual property and technical information; "fees for technical services" covers managerial, technical or consultative services provided otherwise than by an employee. Source taxation does not apply where the beneficial owner's receipts are effectively connected with a permanent establishment or fixed base in the source State. Special-relationship adjustments and an anti-abuse provision further limit application. en-us Sat, 19 Jan 2008 22:45:54 +0530 Sat, 23 Nov 2024 10:48:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=6194 Source-state may tax royalties and fees for technical services paid to a nonresident, but where the recipient is the beneficial owner a ceiling limits the source tax. "Royalties" is defined to include payments for use or right to use intellectual property and technical information; "fees for technical services" covers managerial, technical or consultative services provided otherwise than by an employee. Source taxation does not apply where the beneficial owner's receipts are effectively connected with a permanent establishment or fixed base in the source State. Special-relationship adjustments and an anti-abuse provision further limit application. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=6194