https://www.taxtmi.com/acts?id=45419 Article 13 permits residence-state taxation but allows the source State to tax royalties and fees for technical services paid to residents of the other Contracting State subject to specified withholding caps and categorical distinctions. It defines "royalties" to include payments for use of intellectual property and equipment, and defines "fees for technical services" to encompass ancillary services, know how transfers, and technical plans, while listing explicit exclusions. Nexus and anti abuse rules displace source state treatment where amounts are effectively connected with a permanent establishment or fixed base, apply arm's length adjustments for related party excess payments, and bar treaty benefits when obtaining them was a principal purpose of a transaction. en-us Fri, 18 Oct 2024 13:24:18 +0530 Tue, 22 Oct 2024 17:41:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45419 Article 13 permits residence-state taxation but allows the source State to tax royalties and fees for technical services paid to residents of the other Contracting State subject to specified withholding caps and categorical distinctions. It defines "royalties" to include payments for use of intellectual property and equipment, and defines "fees for technical services" to encompass ancillary services, know how transfers, and technical plans, while listing explicit exclusions. Nexus and anti abuse rules displace source state treatment where amounts are effectively connected with a permanent establishment or fixed base, apply arm's length adjustments for related party excess payments, and bar treaty benefits when obtaining them was a principal purpose of a transaction. Act-Rules DTAA Fri, 18 Oct 2024 13:24:18 +0530 https://www.taxtmi.com/acts?id=45419