https://www.taxtmi.com/acts?id=18908 Article 12 permits taxation of royalties and fees for technical services in both the recipient's State and the source State, with a capped tax in the source State where the beneficial owner is a resident of the other Contracting State. The Article defines royalties and fees for technical services, excludes cases where amounts are effectively connected with a permanent establishment or fixed base (in which case business profits or independent personal services provisions apply), deems when such payments arise in a Contracting State, and requires arm's-length adjustment for amounts inflated by special relationships. en-us Tue, 12 Aug 2014 13:40:53 +0530 Tue, 26 Nov 2024 18:08:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=18908 Article 12 permits taxation of royalties and fees for technical services in both the recipient's State and the source State, with a capped tax in the source State where the beneficial owner is a resident of the other Contracting State. The Article defines royalties and fees for technical services, excludes cases where amounts are effectively connected with a permanent establishment or fixed base (in which case business profits or independent personal services provisions apply), deems when such payments arise in a Contracting State, and requires arm's-length adjustment for amounts inflated by special relationships. Act-Rules DTAA Tue, 12 Aug 2014 13:40:53 +0530 https://www.taxtmi.com/acts?id=18908