https://www.taxtmi.com/manuals?id=4463 Article 12A grants concurrent taxing rights over fees for technical services: the source State may tax such fees but, where the beneficial owner is resident in the other Contracting State, source taxation is capped at a negotiated percentage of gross fees. Exceptions apply when fees are effectively connected with a permanent establishment or fixed base in the source State, in which case Articles 7 or 14 apply. Deemed-source rules, an arm's-length/related-party adjustment rule for excess payments, and a definition excluding employees, educational teaching and personal-use services are included. India has parallel domestic provisions addressing these fees. en-us Wed, 07 Feb 2024 14:55:00 +0530 Wed, 14 Feb 2024 17:34:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/manuals?id=4463 Article 12A grants concurrent taxing rights over fees for technical services: the source State may tax such fees but, where the beneficial owner is resident in the other Contracting State, source taxation is capped at a negotiated percentage of gross fees. Exceptions apply when fees are effectively connected with a permanent establishment or fixed base in the source State, in which case Articles 7 or 14 apply. Deemed-source rules, an arm's-length/related-party adjustment rule for excess payments, and a definition excluding employees, educational teaching and personal-use services are included. India has parallel domestic provisions addressing these fees. Manuals Income Tax Wed, 07 Feb 2024 14:55:00 +0530 https://www.taxtmi.com/manuals?id=4463