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    The Source Rule in International Taxation: Tax Implications for Non-Resident Service Providers
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    Case LawsIncome Tax
    The Source Rule in International Taxation: Tax Implications for Non-Resident Service Providers
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    Source rule protects payments for services used to earn income abroad from domestic taxation when characterised accordingly.
    Whether aircraft maintenance and repair by a non-resident constitutes technical services is addressed by reference to the specialised expertise, regulatory and safety obligations distinguishing such services from ordinary repairs; contemporaneously, retrospective statutory amendments clarifying taxation of fees for technical services are balanced against the source rule exception, under which payments for services used to earn income abroad are not taxed domestically.

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