https://www.taxtmi.com/acts?id=20722 Payments characterised as royalties and fees for technical services may be taxed in the recipient's State while the source State may also tax them subject to a limited withholding cap when the beneficial owner is resident elsewhere. Definitions specify the scope of royalties and technical service fees; connection rules exclude payments effectively connected with a permanent establishment or fixed base, applying business profits or independent services provisions instead. Deeming rules attribute source to payer residence or the permanent establishment bearing the liability, and related-party adjustments confine treaty treatment to the arm's-length portion. en-us Mon, 28 Mar 2016 14:23:17 +0530 Thu, 28 Nov 2024 16:30:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=20722 Payments characterised as royalties and fees for technical services may be taxed in the recipient's State while the source State may also tax them subject to a limited withholding cap when the beneficial owner is resident elsewhere. Definitions specify the scope of royalties and technical service fees; connection rules exclude payments effectively connected with a permanent establishment or fixed base, applying business profits or independent services provisions instead. Deeming rules attribute source to payer residence or the permanent establishment bearing the liability, and related-party adjustments confine treaty treatment to the arm's-length portion. Act-Rules DTAA Mon, 28 Mar 2016 14:23:17 +0530 https://www.taxtmi.com/acts?id=20722