Fees for Technical Services

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....ording to the laws of that State, but if the recipient is the beneficial owner of the fees for technical services, the tax so charged shall not exceed 10 per cent of the gross amount of the fees for technical services. 3. The term "fees for technical services" as used in this article means payments of any kind received as a consideration for services of a managerial, technical or consultancy na....

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....as the case may be, shall apply. 5. Fees for technical services shall be deemed to arise in a contracting State when the services are rendered in that State and the payer is that State itself, a political sub-division, a local authority or a resident of that State. Where, however, the person paying the fees for technical services, whether he is a resident of a contracting State or not, has in a....

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....ccording to the laws of each contracting State, due regard being had to the other provisions of this Convention. 7. The provisions of paragraphs 1 to 6 of this article shall not apply to payments relating to services mentioned hereinbelow : (i) Services that are ancillary and subsidiary, and inextricably and essentially linked, to a sale of property; (ii) Services that are anc....