Royalties and Fees for Technical Services

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....authorities of the State shall by mutual agreement settle the mode of application of paragraph 2. ^4[4. the term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning or scientific experience.] 5. For purposes of this Article, "Fees for technical services" means payments of any kind to any person in consideration for the rendering of any technical or Consultancy services (including through the provisions of services of technical or other personnel) if such services. ....

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....tate independent personal services from a fixed base situated therein and the royalties or fees for technical services are effectively connected with such permanent establishment or fixed base. In such case, the provisions of Article 7 or Article 14, as the case may be, shall apply. 8. Royalties or fees for technical services shall be deemed to arise in one of the States when 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 royalties or fees for technical services, whether he is a resident of one of the States or not, has in one of the State a permanent establishment or a fixed base in connection with which the contract under which the royalties ....

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....re ancillary and subsidiary to the rental of ships, aircraft, containers or other equipment used in connection with the operation of ships or aircraft in international traffic; c) for teaching in or by educational institutions; d) for services for the personal use of the individual or individuals making the payments ; or e) to an employee of the person making the payments or to any individuals or partnership or professional service as defined in Article 14 (Independent personal services) of this Convention." 3.  Substituted Vide Notification No. SO 693(E), dated 30-8-1999, w.e.f. 1-4-1997 before it was read as,  "2. However, such royalties and fees for technical services may al....