https://www.taxtmi.com/acts?id=16750 Cross-border royalties and fees for technical services may be taxed in the source State, but where the beneficial owner is resident in the other Contracting State the source tax is limited to a reduced rate. "Royalties" covers payments for use of intellectual property, equipment or proprietary information; "fees for technical services" covers managerial, technical or consultancy services including provision of personnel. If the beneficial owner carries on business via a permanent establishment or fixed base and the payments are effectively connected, rules for business profits or independent personal services apply. Deemed-source rules follow payer residence or the permanent establishment connection, and special-relationship adjustments limit treaty relief to arm's-length amounts. en-us Tue, 31 Jul 2012 11:43:09 +0530 Sat, 16 Nov 2024 12:40:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=16750 Cross-border royalties and fees for technical services may be taxed in the source State, but where the beneficial owner is resident in the other Contracting State the source tax is limited to a reduced rate. "Royalties" covers payments for use of intellectual property, equipment or proprietary information; "fees for technical services" covers managerial, technical or consultancy services including provision of personnel. If the beneficial owner carries on business via a permanent establishment or fixed base and the payments are effectively connected, rules for business profits or independent personal services apply. Deemed-source rules follow payer residence or the permanent establishment connection, and special-relationship adjustments limit treaty relief to arm's-length amounts. Act-Rules DTAA Tue, 31 Jul 2012 11:43:09 +0530 https://www.taxtmi.com/acts?id=16750