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- Article 12(4) - India USA Treaty - Fee for included services - CA Final International Taxation Elective Paper 6C - CA Arinjay Jain
ARTICLE 12 (4) – INDIA USA TREATY – FEE FOR INCLUDED SERVICES
For purposes of this Article, "fees for included services" means payments of any kind to any person in consideration for the rendering of any technical or consultancy services (including through the provision of services of technical or other personnel) if such services :
(a) are ancillary and subsidiary to the application or enjoyment of the right, property or information for which a payment described in paragraph 3 is received ; or
(b) make available technical knowledge, experience, skill, know-how, or processes, or consist of the development and transfer of a technical plan or technical design.
