https://www.taxtmi.com/acts?id=18211 Article 12 sets rules for taxation of royalties and fees for technical services: such payments may be taxed in the recipient's State and also in the source State, but where the beneficial owner is resident in the other Contracting State the source tax is limited to 10 per cent of the gross amount. Source is determined by payer residence or by the location of the payer's permanent establishment or fixed base that bears the liability. Payments connected with a permanent establishment or fixed base, or where the beneficial owner carries on business or performs services from such a base, are governed by Articles 7 or 14. Related-party excess payments are limited to the arm's-length amount for treaty relief. en-us Fri, 21 Mar 2014 17:08:30 +0530 Mon, 25 Nov 2024 17:52:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=18211 Article 12 sets rules for taxation of royalties and fees for technical services: such payments may be taxed in the recipient's State and also in the source State, but where the beneficial owner is resident in the other Contracting State the source tax is limited to 10 per cent of the gross amount. Source is determined by payer residence or by the location of the payer's permanent establishment or fixed base that bears the liability. Payments connected with a permanent establishment or fixed base, or where the beneficial owner carries on business or performs services from such a base, are governed by Articles 7 or 14. Related-party excess payments are limited to the arm's-length amount for treaty relief. Act-Rules DTAA Fri, 21 Mar 2014 17:08:30 +0530 https://www.taxtmi.com/acts?id=18211