https://www.taxtmi.com/acts?id=45073 Article allocates taxation of royalties and fees for technical services between source and residence: such payments may be taxed in the recipient's residence and may also be taxed in the source State subject to a capped source-State tax when the beneficial owner is resident elsewhere. Definitions specify covered payments for use of intellectual property and for managerial, technical or consultancy services. Payments effectively connected with a permanent establishment or fixed base are taxed under the rules for business profits or independent personal services. Special-relationship pricing is adjusted to arm's-length amounts, with excess taxable under domestic law. en-us Wed, 16 Oct 2024 18:25:08 +0530 Tue, 22 Oct 2024 14:20:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45073 Article allocates taxation of royalties and fees for technical services between source and residence: such payments may be taxed in the recipient's residence and may also be taxed in the source State subject to a capped source-State tax when the beneficial owner is resident elsewhere. Definitions specify covered payments for use of intellectual property and for managerial, technical or consultancy services. Payments effectively connected with a permanent establishment or fixed base are taxed under the rules for business profits or independent personal services. Special-relationship pricing is adjusted to arm's-length amounts, with excess taxable under domestic law. Act-Rules DTAA Wed, 16 Oct 2024 18:25:08 +0530 https://www.taxtmi.com/acts?id=45073