https://www.taxtmi.com/acts?id=44853 Royalties and technical service fees paid to a resident of the other Contracting State may be taxed in the recipient's State but may also be taxed at source with a statutory maximum withholding when the recipient is the beneficial owner. The Article sets broad definitions for "royalties" and "fees for technical services," excludes payments effectively connected with a permanent establishment or fixed base from this Article, deems source by payer residence or by liability borne by a permanent establishment or fixed base, and limits the Article's application to arm's-length amounts where special relationships inflate payments. en-us Wed, 16 Oct 2024 15:53:40 +0530 Tue, 22 Oct 2024 15:11:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=44853 Royalties and technical service fees paid to a resident of the other Contracting State may be taxed in the recipient's State but may also be taxed at source with a statutory maximum withholding when the recipient is the beneficial owner. The Article sets broad definitions for "royalties" and "fees for technical services," excludes payments effectively connected with a permanent establishment or fixed base from this Article, deems source by payer residence or by liability borne by a permanent establishment or fixed base, and limits the Article's application to arm's-length amounts where special relationships inflate payments. Act-Rules DTAA Wed, 16 Oct 2024 15:53:40 +0530 https://www.taxtmi.com/acts?id=44853