https://www.taxtmi.com/acts?id=17112 Fees for technical services are taxable in both the recipient's residence State and the State where they arise, but source-state taxation is limited when the beneficial owner is resident of the other Contracting State. The Article defines such fees to include managerial, technical or consultancy services and excludes certain other service categories. The limitation does not apply when fees are effectively connected with a permanent establishment or fixed base, in which case rules on business profits or independent personal services govern. Special-relationship payments exceeding arm's-length amounts are adjusted and excess remains taxable under domestic law. en-us Thu, 31 Jan 2013 16:34:16 +0530 Tue, 26 Nov 2024 16:43:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=17112 Fees for technical services are taxable in both the recipient's residence State and the State where they arise, but source-state taxation is limited when the beneficial owner is resident of the other Contracting State. The Article defines such fees to include managerial, technical or consultancy services and excludes certain other service categories. The limitation does not apply when fees are effectively connected with a permanent establishment or fixed base, in which case rules on business profits or independent personal services govern. Special-relationship payments exceeding arm's-length amounts are adjusted and excess remains taxable under domestic law. Act-Rules DTAA Thu, 31 Jan 2013 16:34:16 +0530 https://www.taxtmi.com/acts?id=17112