https://www.taxtmi.com/acts?id=18947 Royalties and fees for technical services paid to a resident of the other Contracting State may be taxed in that resident State, and may also be taxed in the source State subject to a maximum tax where the beneficial owner is resident in the other State. Royalties cover payments for use or rights to intellectual property, equipment or technical information; fees for technical services cover managerial, technical or consultancy services and provision of personnel. Payments effectively connected to a permanent establishment or fixed base are taxed under other Articles, and only the arm's-length amount is covered when related-party pricing exceeds market value. en-us Mon, 01 Sep 2014 13:03:56 +0530 Mon, 18 Nov 2024 16:20:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=18947 Royalties and fees for technical services paid to a resident of the other Contracting State may be taxed in that resident State, and may also be taxed in the source State subject to a maximum tax where the beneficial owner is resident in the other State. Royalties cover payments for use or rights to intellectual property, equipment or technical information; fees for technical services cover managerial, technical or consultancy services and provision of personnel. Payments effectively connected to a permanent establishment or fixed base are taxed under other Articles, and only the arm's-length amount is covered when related-party pricing exceeds market value. Act-Rules DTAA Mon, 01 Sep 2014 13:03:56 +0530 https://www.taxtmi.com/acts?id=18947