https://www.taxtmi.com/acts?id=18005 Royalties and technical service fees paid cross border may be taxed in the recipient's residence and also in the source state, but where the beneficial owner is resident of the other Contracting State the source tax is limited by a withholding cap. Definitions specify covered payments for rights, use of equipment, information, and managerial, technical or consultancy services. Source taxation exceptions apply when amounts are effectively connected with a permanent establishment or fixed base, in which case business profits or independent personal services rules govern. Related party excess payments are limited to arm's length amounts for the Article's benefits. en-us Mon, 22 Jul 2013 16:44:19 +0530 Mon, 18 Nov 2024 12:20:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=18005 Royalties and technical service fees paid cross border may be taxed in the recipient's residence and also in the source state, but where the beneficial owner is resident of the other Contracting State the source tax is limited by a withholding cap. Definitions specify covered payments for rights, use of equipment, information, and managerial, technical or consultancy services. Source taxation exceptions apply when amounts are effectively connected with a permanent establishment or fixed base, in which case business profits or independent personal services rules govern. Related party excess payments are limited to arm's length amounts for the Article's benefits. Act-Rules DTAA Mon, 22 Jul 2013 16:44:19 +0530 https://www.taxtmi.com/acts?id=18005