https://www.taxtmi.com/acts?id=44728 Royalties and fees for technical services arising in one Contracting State may be taxed in the State of residence of the recipient but may also be taxed in the State of source with a limited withholding where the beneficial owner is resident of the other State. The Article defines royalties and fees for technical services, excludes employee remuneration, deems source by payer residence or by permanent establishment/fixed base connection, and restricts treaty relief where payments exceed arm's-length amounts due to special relationships. en-us Wed, 16 Oct 2024 14:21:07 +0530 Tue, 22 Oct 2024 15:44:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=44728 Royalties and fees for technical services arising in one Contracting State may be taxed in the State of residence of the recipient but may also be taxed in the State of source with a limited withholding where the beneficial owner is resident of the other State. The Article defines royalties and fees for technical services, excludes employee remuneration, deems source by payer residence or by permanent establishment/fixed base connection, and restricts treaty relief where payments exceed arm's-length amounts due to special relationships. Act-Rules DTAA Wed, 16 Oct 2024 14:21:07 +0530 https://www.taxtmi.com/acts?id=44728