https://www.taxtmi.com/acts?id=6320 Management and consultancy fees may be taxed in the resident State of the recipient and may also be taxed in the State where they arise, subject to a Convention limit on the tax charged. The definition covers payments to non-employees for managerial, technical or consultancy services. If the recipient has a permanent establishment in the source State and the services are effectively connected there, the business profits rules apply. Fees are deemed to arise in the payer's State or, where borne by a permanent establishment, in the State of that permanent establishment. Related party excess payments are limited to the arm's length amount. en-us Sat, 19 Jan 2008 22:45:54 +0530 Mon, 25 Nov 2024 12:15:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=6320 Management and consultancy fees may be taxed in the resident State of the recipient and may also be taxed in the State where they arise, subject to a Convention limit on the tax charged. The definition covers payments to non-employees for managerial, technical or consultancy services. If the recipient has a permanent establishment in the source State and the services are effectively connected there, the business profits rules apply. Fees are deemed to arise in the payer's State or, where borne by a permanent establishment, in the State of that permanent establishment. Related party excess payments are limited to the arm's length amount. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=6320