On the other hand, in a contract for the provision of services such as accounting services, legal advice, drafting and reviewing contract, etc., where one party undertakes to use the customary skills of his calling to execute work himself for the other party, the payments made for the provision of such services would not constitute royalties under Article 13 of the DTA. In relation to such services, the know-how is utilised by the service provider in performing his work and there is no transfer of know-how to the recipient of the services ie the client.