https://www.taxtmi.com/acts?id=10378 Fees for technical services may be taxed in the recipient's State, while the State where they arise may also tax them subject to a withholding tax limitation when the beneficial owner is resident of the other State. The term covers managerial, technical or consultancy services (including personnel) but excludes services under Articles 15 and 16. Exceptions apply where the beneficial owner operates through a permanent establishment or fixed base and the fees are effectively connected; in such cases rules on business profits or independent personal services govern. Deemed source rules and special-relationship arm's-length adjustments also apply. en-us Sat, 17 Jan 2009 19:00:38 +0530 Tue, 26 Nov 2024 12:29:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=10378 Fees for technical services may be taxed in the recipient's State, while the State where they arise may also tax them subject to a withholding tax limitation when the beneficial owner is resident of the other State. The term covers managerial, technical or consultancy services (including personnel) but excludes services under Articles 15 and 16. Exceptions apply where the beneficial owner operates through a permanent establishment or fixed base and the fees are effectively connected; in such cases rules on business profits or independent personal services govern. Deemed source rules and special-relationship arm's-length adjustments also apply. Act-Rules DTAA Sat, 17 Jan 2009 19:00:38 +0530 https://www.taxtmi.com/acts?id=10378