https://www.taxtmi.com/acts?id=8876 Taxation of technical fees grants taxing rights to the recipient's residence State while permitting the source State to tax fees arising there, limited to ten percent of the gross amount when the beneficial owner resides in the other Contracting State. Fees for technical, managerial or consultancy services that are effectively connected with a permanent establishment or fixed base are excluded and taxed under the rules for business profits or independent personal services. Source is generally where the payer resides, or where the permanent establishment that incurred the obligation is situated; amounts exceeding arm's-length consideration remain taxable under domestic law. en-us Sat, 21 Jun 2008 11:27:28 +0530 Wed, 06 Nov 2024 15:35:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=8876 Taxation of technical fees grants taxing rights to the recipient's residence State while permitting the source State to tax fees arising there, limited to ten percent of the gross amount when the beneficial owner resides in the other Contracting State. Fees for technical, managerial or consultancy services that are effectively connected with a permanent establishment or fixed base are excluded and taxed under the rules for business profits or independent personal services. Source is generally where the payer resides, or where the permanent establishment that incurred the obligation is situated; amounts exceeding arm's-length consideration remain taxable under domestic law. Act-Rules DTAA Sat, 21 Jun 2008 11:27:28 +0530 https://www.taxtmi.com/acts?id=8876