https://www.taxtmi.com/acts?id=18981 Taxation of royalties and fees for technical or professional services permits residence taxation of receipts and source taxation of payments arising in a Contracting State subject to a treaty ceiling for beneficial owners resident in the other State; royalties and fees are defined by reference to use of intellectual property, equipment, information and provision of managerial, technical, consultancy or independent professional services. Where the beneficial owner has a permanent establishment in the source State and the rights or services are effectively connected thereto, business profits rules govern. Deemed source rules and arm's length adjustments determine taxable amounts. en-us Fri, 12 Sep 2014 13:45:35 +0530 Tue, 05 Nov 2024 18:07:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=18981 Taxation of royalties and fees for technical or professional services permits residence taxation of receipts and source taxation of payments arising in a Contracting State subject to a treaty ceiling for beneficial owners resident in the other State; royalties and fees are defined by reference to use of intellectual property, equipment, information and provision of managerial, technical, consultancy or independent professional services. Where the beneficial owner has a permanent establishment in the source State and the rights or services are effectively connected thereto, business profits rules govern. Deemed source rules and arm's length adjustments determine taxable amounts. Act-Rules DTAA Fri, 12 Sep 2014 13:45:35 +0530 https://www.taxtmi.com/acts?id=18981