https://www.taxtmi.com/acts?id=45202 The DTAA allocates taxation of cross border royalties and fees for technical services between source and residence States, permits source State taxation subject to a limit where the recipient is beneficial owner, defines royalties and technical service fees broadly, excludes payments effectively connected with a permanent establishment or fixed base from these rules, and applies deemed source and related party arm's length adjustment provisions. en-us Thu, 17 Oct 2024 16:45:46 +0530 Tue, 22 Oct 2024 16:44:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45202 The DTAA allocates taxation of cross border royalties and fees for technical services between source and residence States, permits source State taxation subject to a limit where the recipient is beneficial owner, defines royalties and technical service fees broadly, excludes payments effectively connected with a permanent establishment or fixed base from these rules, and applies deemed source and related party arm's length adjustment provisions. Act-Rules DTAA Thu, 17 Oct 2024 16:45:46 +0530 https://www.taxtmi.com/acts?id=45202