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Taxation of income from services‣ ¾ Option 3: a narrow provision restricted to services performedin the source country, with a time threshold for source countrytax and taxation on a net basis. 74A majority of the Committee decided to proceed with the draftingof the wording for a new article and Commentary along the linesof Option 1. 754.11.2 The treatment of technical services under domestic lawAs discussed above, some developing countries have special rules intheir domestic law and tax treaties for income from technical servicesderived by non-residents. One basic difficulty with these rules is thatthe types of services to which the rules apply are often not definedprecisely. Some countries distinguish between technical assistance,which generally involves a transfer of know-how or technical expertise(analogous to the transfer of the right to use intellectual property), andtechnical services, which involve the application of specialized knowledgeor skills.The definition of technical services is similarly problematicunder the provisions of tax treaties. According to an IBFD study carriedout in 2011, 76 134 out of 1,586 bilateral tax treaties concludedin the period 1997 – 2011 contained a special provision dealing with“managerial, technical and consulting services” without defining suchservices. Some countries, such as India, extend Article 12 dealing withroyalties to include payments for services that are ancillary or subsidiaryto the application of intellectual property or that make available74See “Note on a New Article of the United Nations Model ConventionDealing with the Taxation of Fees for Technical and Other Services,” 11 October2013, presented at the ninth session of the United Nations Committee ofExperts (21 – 25 October 2013), E/C.18/2013/CRP.5, available at http://www.un.org/esa/ffd/wp-content/uploads/2014/09/9STM_CRP5_Services.pdf.75United Nations, Economic and Social Council, Committee of Expertson International Cooperation in Tax Matters, Report on the ninth session(21-25 October 2013), chapter III, section K, available at http://www.un.org/ga/search/view_doc.asp?symbol=E/2013/45&Lang=E.76See W. Wijnen, J. de Goede and A. Alessi, “The Treatment of Servicesin Tax Treaties,” supra note 71.91