https://www.taxtmi.com/acts?id=32330 Article 12A permits the state where fees for technical services arise to tax such payments, with a limited source-state tax when the beneficial owner is resident in the other Contracting State. The Article defines the payments, excludes services covered by other Articles, disapplies source taxation where amounts are effectively connected to a permanent establishment or fixed base (invoking business profits or independent personal services rules), and subjects related party excess payments to arm's length adjustment. en-us Tue, 15 May 2018 18:47:55 +0530 Thu, 28 Nov 2024 12:02:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=32330 Article 12A permits the state where fees for technical services arise to tax such payments, with a limited source-state tax when the beneficial owner is resident in the other Contracting State. The Article defines the payments, excludes services covered by other Articles, disapplies source taxation where amounts are effectively connected to a permanent establishment or fixed base (invoking business profits or independent personal services rules), and subjects related party excess payments to arm's length adjustment. Act-Rules DTAA Tue, 15 May 2018 18:47:55 +0530 https://www.taxtmi.com/acts?id=32330