https://www.taxtmi.com/acts?id=16699 Article 12 permits both residence-State and source-State taxation of royalties and fees for technical services, but limits source-State withholding when the beneficial owner is resident in the other Contracting State. It defines royalties and fees for technical services, excludes application where the beneficial owner has a permanent establishment or fixed base in the source State and the payments are effectively connected with that presence, deems when such payments arise, and requires arm's-length adjustment where special relationships affect the amount. en-us Mon, 25 Jun 2012 12:35:02 +0530 Tue, 27 Aug 2024 14:32:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=16699 Article 12 permits both residence-State and source-State taxation of royalties and fees for technical services, but limits source-State withholding when the beneficial owner is resident in the other Contracting State. It defines royalties and fees for technical services, excludes application where the beneficial owner has a permanent establishment or fixed base in the source State and the payments are effectively connected with that presence, deems when such payments arise, and requires arm's-length adjustment where special relationships affect the amount. Act-Rules DTAA Mon, 25 Jun 2012 12:35:02 +0530 https://www.taxtmi.com/acts?id=16699