https://www.taxtmi.com/acts?id=32273 Fees for management, professional and technical services arising in one Contracting State and paid to a resident of the other may be taxed in that resident State, but the source State may tax them subject to a withholding tax cap if the beneficial owner is resident of the other State. The definition excludes employees and items in Articles 15 and 16. If fees are effectively connected with a permanent establishment or fixed base in the source State, provisions for business profits or independent personal services apply. Special relationship adjustments limit taxation to arm's length amounts. en-us Tue, 15 May 2018 17:30:12 +0530 Mon, 09 Dec 2024 11:25:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=32273 Fees for management, professional and technical services arising in one Contracting State and paid to a resident of the other may be taxed in that resident State, but the source State may tax them subject to a withholding tax cap if the beneficial owner is resident of the other State. The definition excludes employees and items in Articles 15 and 16. If fees are effectively connected with a permanent establishment or fixed base in the source State, provisions for business profits or independent personal services apply. Special relationship adjustments limit taxation to arm's length amounts. Act-Rules DTAA Tue, 15 May 2018 17:30:12 +0530 https://www.taxtmi.com/acts?id=32273