https://www.taxtmi.com/acts?id=18242 The Article permits taxation of royalties and fees for technical services in both the source State and the resident State, subject to a limited tax where the beneficial owner is resident in the other Contracting State. It sets source rules deeming income to arise where the payer is resident or where a payer's permanent establishment or fixed base incurs the liability, and deems income to arise in the State where use, rights or services relate. Definitions specify royalties (including copyrights, software, patents, equipment, and technical information) and fees for technical services (managerial, technical or consultancy services). Special relationship adjustments limit Article application to arm's length amounts; excess remains taxable under domestic law. en-us Sun, 23 Mar 2014 14:55:03 +0530 Wed, 28 Aug 2024 16:07:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=18242 The Article permits taxation of royalties and fees for technical services in both the source State and the resident State, subject to a limited tax where the beneficial owner is resident in the other Contracting State. It sets source rules deeming income to arise where the payer is resident or where a payer's permanent establishment or fixed base incurs the liability, and deems income to arise in the State where use, rights or services relate. Definitions specify royalties (including copyrights, software, patents, equipment, and technical information) and fees for technical services (managerial, technical or consultancy services). Special relationship adjustments limit Article application to arm's length amounts; excess remains taxable under domestic law. Act-Rules DTAA Sun, 23 Mar 2014 14:55:03 +0530 https://www.taxtmi.com/acts?id=18242