https://www.taxtmi.com/acts?id=45610 arising in one Contracting State and paid to a resident of the other may be taxed in the recipient's State of residence, but may also be taxed in the State where they arise; if the beneficial owner is resident of the other State the source tax shall not exceed 20% of the gross amount. Definitions: "royalties" cover payments for use of copyrights, films, patents, trademarks, designs, plans, secret formulas, equipment and technical information; "fees for technical services" cover managerial, technical or consultancy services and provision of technical personnel, excluding employee remuneration and specified independent personal services. Special rules apply where amounts are effectively connected with a permanent establishment or fixed base, and related-party excess amounts are limited to arm's-length values. en-us Fri, 18 Oct 2024 18:15:53 +0530 Wed, 23 Oct 2024 16:11:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45610 arising in one Contracting State and paid to a resident of the other may be taxed in the recipient's State of residence, but may also be taxed in the State where they arise; if the beneficial owner is resident of the other State the source tax shall not exceed 20% of the gross amount. Definitions: "royalties" cover payments for use of copyrights, films, patents, trademarks, designs, plans, secret formulas, equipment and technical information; "fees for technical services" cover managerial, technical or consultancy services and provision of technical personnel, excluding employee remuneration and specified independent personal services. Special rules apply where amounts are effectively connected with a permanent establishment or fixed base, and related-party excess amounts are limited to arm's-length values. Act-Rules DTAA Fri, 18 Oct 2024 18:15:53 +0530 https://www.taxtmi.com/acts?id=45610