https://www.taxtmi.com/acts?id=45107 Article 12 permits residence-state taxation and allows source-state taxation of royalties and fees for technical services, subject to a reduced withholding when the beneficial owner is resident in the other Contracting State. It defines royalties and fees for technical services, exempts the reduced source treatment when amounts are effectively connected with a permanent establishment or fixed base (where Articles on business profits or independent personal services apply), sets deeming rules for source determination, and limits treaty relief where related parties inflate payments above arm's length amounts. en-us Thu, 17 Oct 2024 14:35:25 +0530 Tue, 22 Oct 2024 11:54:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45107 Article 12 permits residence-state taxation and allows source-state taxation of royalties and fees for technical services, subject to a reduced withholding when the beneficial owner is resident in the other Contracting State. It defines royalties and fees for technical services, exempts the reduced source treatment when amounts are effectively connected with a permanent establishment or fixed base (where Articles on business profits or independent personal services apply), sets deeming rules for source determination, and limits treaty relief where related parties inflate payments above arm's length amounts. Act-Rules DTAA Thu, 17 Oct 2024 14:35:25 +0530 https://www.taxtmi.com/acts?id=45107