https://www.taxtmi.com/acts?id=44666 Article 12 permits source state taxation of royalties and fees for technical services paid to a resident of the other Contracting State, subject to a limited withholding tax when the beneficial owner is resident in the other State. It defines royalties and fees for technical services, excludes amounts connected with aircraft and ships, and provides that payments effectively connected to a permanent establishment or fixed base are taxed under the provisions for business profits or independent personal services. An arm's length rule limits application where related party pricing inflates payments. en-us Wed, 16 Oct 2024 12:44:05 +0530 Tue, 22 Oct 2024 11:31:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=44666 Article 12 permits source state taxation of royalties and fees for technical services paid to a resident of the other Contracting State, subject to a limited withholding tax when the beneficial owner is resident in the other State. It defines royalties and fees for technical services, excludes amounts connected with aircraft and ships, and provides that payments effectively connected to a permanent establishment or fixed base are taxed under the provisions for business profits or independent personal services. An arm's length rule limits application where related party pricing inflates payments. Act-Rules DTAA Wed, 16 Oct 2024 12:44:05 +0530 https://www.taxtmi.com/acts?id=44666