https://www.taxtmi.com/acts?id=44697 The Article permits both source and residence state taxation of royalties and fees for included services but caps source-state withholding when the beneficial owner is a resident of the other Contracting State, with different ceilings by payment category and transitional rates for certain cases. It defines royalties and fees for included services, lists specific exclusions, treats payments as arising where the payer or relevant permanent establishment is situated, and excludes treaty relief where payments are effectively connected with a permanent establishment or fixed base, applying arm's-length adjustments for related-party distortions. en-us Wed, 16 Oct 2024 13:15:04 +0530 Wed, 23 Oct 2024 16:18:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=44697 The Article permits both source and residence state taxation of royalties and fees for included services but caps source-state withholding when the beneficial owner is a resident of the other Contracting State, with different ceilings by payment category and transitional rates for certain cases. It defines royalties and fees for included services, lists specific exclusions, treats payments as arising where the payer or relevant permanent establishment is situated, and excludes treaty relief where payments are effectively connected with a permanent establishment or fixed base, applying arm's-length adjustments for related-party distortions. Act-Rules DTAA Wed, 16 Oct 2024 13:15:04 +0530 https://www.taxtmi.com/acts?id=44697