https://www.taxtmi.com/acts?id=14924 Payments defined as royalties and fees for technical services may be taxed in the recipient's State of residence but may also be taxed in the source State, subject to a capped tax when the beneficial owner is a resident of the other Contracting State. Definitions cover use or right to use copyrights, patents, trademarks, designs, secret formulas, equipment and information, and managerial, technical or consultancy services. If rights or services are effectively connected with a permanent establishment or fixed base in the source State, rules for business profits or independent personal services apply. Special-relationship pricing limits treaty application to arm's-length amounts. en-us Tue, 30 Aug 2011 11:40:17 +0530 Mon, 18 Nov 2024 18:31:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=14924 Payments defined as royalties and fees for technical services may be taxed in the recipient's State of residence but may also be taxed in the source State, subject to a capped tax when the beneficial owner is a resident of the other Contracting State. Definitions cover use or right to use copyrights, patents, trademarks, designs, secret formulas, equipment and information, and managerial, technical or consultancy services. If rights or services are effectively connected with a permanent establishment or fixed base in the source State, rules for business profits or independent personal services apply. Special-relationship pricing limits treaty application to arm's-length amounts. Act-Rules DTAA Tue, 30 Aug 2011 11:40:17 +0530 https://www.taxtmi.com/acts?id=14924