https://www.taxtmi.com/acts?id=37675 Royalties and fees for technical services may be taxed in the resident State of the recipient, while the source State may also tax such payments subject to a withholding limit where the beneficial owner is resident of the other State. Royalties are broadly defined to include payments for use of copyrights, patents, trademarks, designs, equipment and technical information. Fees for technical services include managerial, technical or consultancy services and provision of personnel. If the beneficial owner has a permanent establishment or fixed base in the source State and the rights are effectively connected, business profits or independent service provisions apply. Related-party excess payments are limited to arm's-length amounts for treaty application. en-us Thu, 19 Sep 2019 12:57:06 +0530 Mon, 09 Dec 2024 11:36:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=37675 Royalties and fees for technical services may be taxed in the resident State of the recipient, while the source State may also tax such payments subject to a withholding limit where the beneficial owner is resident of the other State. Royalties are broadly defined to include payments for use of copyrights, patents, trademarks, designs, equipment and technical information. Fees for technical services include managerial, technical or consultancy services and provision of personnel. If the beneficial owner has a permanent establishment or fixed base in the source State and the rights are effectively connected, business profits or independent service provisions apply. Related-party excess payments are limited to arm's-length amounts for treaty application. Act-Rules DTAA Thu, 19 Sep 2019 12:57:06 +0530 https://www.taxtmi.com/acts?id=37675