https://www.taxtmi.com/acts?id=16569 Cross border 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 where they arise; when the beneficial owner is resident in the other Contracting State the source State's tax is limited to a prescribed maximum. "Royalties" cover payments for use of or rights to intellectual property and proprietary information; "fees for technical services" include managerial, technical, consultancy and personnel services. The Article excludes payments effectively connected with a permanent establishment or fixed base in the source State, in which case business profits or independent personal services provisions apply. Related party excess payments are reduced to arm's length amounts for the Article's application. en-us Wed, 30 May 2012 15:47:57 +0530 Tue, 19 Nov 2024 18:09:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=16569 Cross border 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 where they arise; when the beneficial owner is resident in the other Contracting State the source State's tax is limited to a prescribed maximum. "Royalties" cover payments for use of or rights to intellectual property and proprietary information; "fees for technical services" include managerial, technical, consultancy and personnel services. The Article excludes payments effectively connected with a permanent establishment or fixed base in the source State, in which case business profits or independent personal services provisions apply. Related party excess payments are reduced to arm's length amounts for the Article's application. Act-Rules DTAA Wed, 30 May 2012 15:47:57 +0530 https://www.taxtmi.com/acts?id=16569