https://www.taxtmi.com/acts?id=34177 The Article permits source-state taxation of fees for technical services paid to a resident of the other Contracting Party, with a treaty limitation when the beneficial owner is resident of that other Party. It defines such fees to include managerial, technical or consultancy services and excludes independent and dependent personal services. Payments attributable to a permanent establishment or fixed base are treated as arising where that establishment or base is situated, and where special relationships inflate payments, only the arm's-length amount is governed by the Article while excess amounts remain taxable under domestic law. Treaty benefits are denied if one main purpose is treaty-shopping. en-us Fri, 28 Dec 2018 16:39:47 +0530 Thu, 21 Nov 2024 10:51:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=34177 The Article permits source-state taxation of fees for technical services paid to a resident of the other Contracting Party, with a treaty limitation when the beneficial owner is resident of that other Party. It defines such fees to include managerial, technical or consultancy services and excludes independent and dependent personal services. Payments attributable to a permanent establishment or fixed base are treated as arising where that establishment or base is situated, and where special relationships inflate payments, only the arm's-length amount is governed by the Article while excess amounts remain taxable under domestic law. Treaty benefits are denied if one main purpose is treaty-shopping. Act-Rules DTAA Fri, 28 Dec 2018 16:39:47 +0530 https://www.taxtmi.com/acts?id=34177