Management and consultancy fees

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.... State, but the tax so charged shall not exceed 10 per cent of the gross amount of the fees. 3. The term "management and consultancy fees" as used in this article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a managerial, technical or consultancy nature. 4. The provisions of paragraphs (1) an....

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....ablishment, then such fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 6. Where, owing to special relationship between the payer and the recipient or between both of them and some other person, the amount of the management and consultancy fees paid, having regard to the services for which it is paid exceeds the amount which would have been a....