https://www.taxtmi.com/acts?id=15123 arising in a Contracting State and paid to a resident of the other State may be taxed in the recipient's residence; the source State may also tax them but, where the beneficial owner is resident in the other State, source taxation is subject to a capped withholding rate. Royalties cover payments for use of intellectual property and related industrial/commercial/scientific information; fees for technical services cover managerial, technical or consultancy services including technical personnel. The withholding regime does not apply where the beneficial owner has a permanent establishment or fixed base in the source State and the payments are effectively connected there; deemed-source rules and related party arm's length adjustments also apply. en-us Tue, 30 Aug 2011 15:25:43 +0530 Fri, 22 Nov 2024 14:46:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=15123 arising in a Contracting State and paid to a resident of the other State may be taxed in the recipient's residence; the source State may also tax them but, where the beneficial owner is resident in the other State, source taxation is subject to a capped withholding rate. Royalties cover payments for use of intellectual property and related industrial/commercial/scientific information; fees for technical services cover managerial, technical or consultancy services including technical personnel. The withholding regime does not apply where the beneficial owner has a permanent establishment or fixed base in the source State and the payments are effectively connected there; deemed-source rules and related party arm's length adjustments also apply. Act-Rules DTAA Tue, 30 Aug 2011 15:25:43 +0530 https://www.taxtmi.com/acts?id=15123