https://www.taxtmi.com/acts?id=14968 Royalties and fees for technical services arising in one Contracting State and paid to a resident of the other State may be taxed in the resident State, while the source State may also tax such payments subject to a reduced withholding cap for beneficial owners who are residents. The Article defines royalties and fees for technical services, excludes services covered elsewhere, disapplies withholding when amounts are effectively connected with a permanent establishment or fixed base, provides deemed-source rules tied to the payer or its permanent establishment, and limits taxation to arm's-length amounts where special relationships inflate payments. en-us Tue, 30 Aug 2011 12:02:44 +0530 Tue, 26 Nov 2024 14:25:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=14968 Royalties and fees for technical services arising in one Contracting State and paid to a resident of the other State may be taxed in the resident State, while the source State may also tax such payments subject to a reduced withholding cap for beneficial owners who are residents. The Article defines royalties and fees for technical services, excludes services covered elsewhere, disapplies withholding when amounts are effectively connected with a permanent establishment or fixed base, provides deemed-source rules tied to the payer or its permanent establishment, and limits taxation to arm's-length amounts where special relationships inflate payments. Act-Rules DTAA Tue, 30 Aug 2011 12:02:44 +0530 https://www.taxtmi.com/acts?id=14968