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TMI BlogArticle 12A - Fee for Technical ServicesX X X X Extracts X X X X X X X X Extracts X X X X ..... n a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. [ Para 1 of Article 12A ] Rate of tax charge Notwithstanding the provisions of Article 14 and subject to the provisions of Articles 8, 16 and 17, fees for technical services arising in a Contracting State may also be taxed in the Contracting State in which they arise and a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... fectively connected with: (a) such permanent establishment or fixed base, or (b) business activities referred to in (c) of paragraph 1 of Article 7. In such cases the provisions of Article 7 or Article 14, as the case may be, shall apply. [ Para 4 of Article 12A ] Deemed to be arise in Contracting state Fees for technical services shall be deemed to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that other State and such fees are borne by that permanent establishment or fixed base. [ Para 6 of Article 12A ] Taxability of Excess payment made above specified percentage in Para 2 of article 12A Where, by reason of a special relationship between the payer and the beneficial owner of the fees for technical services or between both of them and some ot ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the payment; (b) for teaching in an educational institution or for teaching by an educational institution; or (c) by an individual for services for the personal use of an individual. [ Para 3 of Article 12A ] The term payment has a broad meaning consistent with the meaning of the related term paid in Articles 10 and 11. the concept of payment means the fulfilment of the ob ..... X X X X Extracts X X X X X X X X Extracts X X X X
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