https://www.taxtmi.com/acts?id=45642 Article 13 permits source-state taxation of royalties, fees for technical services and payments for use of equipment but limits withholding when the recipient is the beneficial owner; it defines each category, preserves exceptions where the recipient's income is effectively connected with a permanent establishment or fixed base in the source state (triggering Articles 7 or 15), attributes source where the payer or its permanent establishment bears the payment, and restricts treaty relief to arm's-length amounts where special relationships inflate payments. en-us Wed, 23 Oct 2024 12:33:20 +0530 Wed, 23 Oct 2024 13:10:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45642 Article 13 permits source-state taxation of royalties, fees for technical services and payments for use of equipment but limits withholding when the recipient is the beneficial owner; it defines each category, preserves exceptions where the recipient's income is effectively connected with a permanent establishment or fixed base in the source state (triggering Articles 7 or 15), attributes source where the payer or its permanent establishment bears the payment, and restricts treaty relief to arm's-length amounts where special relationships inflate payments. Act-Rules DTAA Wed, 23 Oct 2024 12:33:20 +0530 https://www.taxtmi.com/acts?id=45642