https://www.taxtmi.com/forum/issue?id=117741 Query whether withholding under domestic law applies to cross border payments for vessel inspection services treated as technical services; the payer notes the DTAA provision for fees for technical services (Article 12) appears to lack an operative rule and asks if DTAA relief applies or whether the payment should be characterised under another treaty or domestic service category to determine the applicable treaty article and withholding consequence. en-us Wed, 29 Dec 2021 18:10:22 +0530 Thu, 23 Jan 2025 15:54:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/forum/issue?id=117741 Query whether withholding under domestic law applies to cross border payments for vessel inspection services treated as technical services; the payer notes the DTAA provision for fees for technical services (Article 12) appears to lack an operative rule and asks if DTAA relief applies or whether the payment should be characterised under another treaty or domestic service category to determine the applicable treaty article and withholding consequence. Discussion-Forum Income Tax Wed, 29 Dec 2021 18:10:22 +0530 https://www.taxtmi.com/forum/issue?id=117741