https://www.taxtmi.com/acts?id=53774 Fees for technical services arising in one Contracting State and paid to a resident of the other Contracting State may be taxed in the State of residence, and may also be taxed in the source State subject to a 10 percent cap on the gross amount where the beneficial owner is a resident of the other State. Fees for technical services mean payments for managerial, technical or consultancy services, subject to exclusions for employee payments, specified teaching payments, and personal-use services. The article also provides source rules, permanent establishment and fixed base exceptions, and an arm's-length limitation where a special relationship inflates the payment. en-us Tue, 31 Mar 2026 14:32:14 +0530 Tue, 31 Mar 2026 14:32:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=53774 Fees for technical services arising in one Contracting State and paid to a resident of the other Contracting State may be taxed in the State of residence, and may also be taxed in the source State subject to a 10 percent cap on the gross amount where the beneficial owner is a resident of the other State. Fees for technical services mean payments for managerial, technical or consultancy services, subject to exclusions for employee payments, specified teaching payments, and personal-use services. The article also provides source rules, permanent establishment and fixed base exceptions, and an arm's-length limitation where a special relationship inflates the payment. Act-Rules DTAA Tue, 31 Mar 2026 14:32:14 +0530 https://www.taxtmi.com/acts?id=53774