https://www.taxtmi.com/acts?id=45290 Article 12 allows royalties and fees for technical services arising in one Contracting State and paid to a resident of the other to be taxed in the recipient's State, while permitting the source State to tax them under its laws subject to a tax limit where the recipient is the beneficial owner. It defines "royalties" and "fees for technical services," excludes payments connected with a permanent establishment or fixed base (in which case business profits or independent personal services rules apply), sets rules for when payments are deemed to arise, and limits application where related party pricing inflates amounts. en-us Fri, 18 Oct 2024 11:29:57 +0530 Fri, 18 Oct 2024 11:29:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45290 Article 12 allows royalties and fees for technical services arising in one Contracting State and paid to a resident of the other to be taxed in the recipient's State, while permitting the source State to tax them under its laws subject to a tax limit where the recipient is the beneficial owner. It defines "royalties" and "fees for technical services," excludes payments connected with a permanent establishment or fixed base (in which case business profits or independent personal services rules apply), sets rules for when payments are deemed to arise, and limits application where related party pricing inflates amounts. Act-Rules DTAA Fri, 18 Oct 2024 11:29:57 +0530 https://www.taxtmi.com/acts?id=45290