https://www.taxtmi.com/acts?id=44635 Article 12 permits residence-state taxation of royalties and fees for technical services but allows the source State to tax amounts arising there, subject to a withholding cap of ten percent where the beneficial owner is resident in the other Contracting State. It defines royalties to include payments for use of copyrights, patents, trademarks, designs, plans, secret formulae, processes, equipment or industrial information, and defines fees for technical services to include managerial, technical or consultancy services including personnel, excluding Articles 14 and 15 services. en-us Wed, 16 Oct 2024 12:14:03 +0530 Tue, 22 Oct 2024 16:33:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=44635 Article 12 permits residence-state taxation of royalties and fees for technical services but allows the source State to tax amounts arising there, subject to a withholding cap of ten percent where the beneficial owner is resident in the other Contracting State. It defines royalties to include payments for use of copyrights, patents, trademarks, designs, plans, secret formulae, processes, equipment or industrial information, and defines fees for technical services to include managerial, technical or consultancy services including personnel, excluding Articles 14 and 15 services. Act-Rules DTAA Wed, 16 Oct 2024 12:14:03 +0530 https://www.taxtmi.com/acts?id=44635