With reference to. Article 12, paragraph 3 - It is understood that the provisions of paragraph 3 of Article 12 shall apply to payments of any kind to any person, other than payments to an employee of a person making such payments, in consideration for the rendering of assistance or services of a managerial, administrative, scientific, technical or consultancy nature.
Appears in 2 contracts
Sources: Convention for the Avoidance of Double Taxation, Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion