https://www.taxtmi.com/acts?id=19348 Payments constituting royalties or fees for technical services arising in one Contracting State and paid to a resident of the other may be taxed in the recipient's State, while the source State may also tax them under its laws subject to a reduced withholding ceiling when the recipient is the beneficial owner. Definitions specify scope of royalties and technical services, and source, permanent establishment/fixed base connection, and special relationship adjustments determine when alternative Articles or arm's length principles apply. en-us Fri, 20 Mar 2015 16:17:10 +0530 Wed, 13 Nov 2024 16:51:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=19348 Payments constituting royalties or fees for technical services arising in one Contracting State and paid to a resident of the other may be taxed in the recipient's State, while the source State may also tax them under its laws subject to a reduced withholding ceiling when the recipient is the beneficial owner. Definitions specify scope of royalties and technical services, and source, permanent establishment/fixed base connection, and special relationship adjustments determine when alternative Articles or arm's length principles apply. Act-Rules DTAA Fri, 20 Mar 2015 16:17:10 +0530 https://www.taxtmi.com/acts?id=19348