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3. The term "fees for technical services" as used in this Article means payments of any kind as consideration for managerial, technical or consultancy services, including through the provision of services of technical or other personnel, but does not include payments for independent personal services and for dependent personal services as mentioned in Articles 15 and 16 respectively of this Agreement.

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29. We find that the payment made to Kyocera Document Solution Asia Limited ('KDAS) by KDID in respect of cost incurred by KDAS are for for arranging various facilities to KDID has been categorized as reimbursement on cost to cost basis. The facilities arranged ranges from Learning courses and PowerPoint development system in the form of Academy Localisation Tool; use of software (Astea); (Ringi); (SBO) for the purpose of Group managed ERP system for resource planning management (support system); use of software (Bliq) which is - comprehensive source of independent research and data.; cloud solution for Computer system resource for data storage on a common server of the company; email hosting for hosting the domain of the company in order to set up a custom email address. For all these facilities, KDAS pays a fee to entities outside India and collects the same from its group entities such as KDID in India availing such facilities on cost to cost basis.