Royalties and technical service fees: source and residence taxation balanced with connection and arm's length limits. Payments defined as royalties and fees for technical services may be taxed in the recipient's State of residence but may also be taxed in the source State, subject to a capped tax when the beneficial owner is a resident of the other Contracting State. Definitions cover use or right to use copyrights, patents, trademarks, designs, secret formulas, equipment and information, and managerial, technical or consultancy services. If rights or services are effectively connected with a permanent establishment or fixed base in the source State, rules for business profits or independent personal services apply. Special-relationship pricing limits treaty application to arm's-length amounts.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Royalties and technical service fees: source and residence taxation balanced with connection and arm's length limits.
Payments defined as royalties and fees for technical services may be taxed in the recipient's State of residence but may also be taxed in the source State, subject to a capped tax when the beneficial owner is a resident of the other Contracting State. Definitions cover use or right to use copyrights, patents, trademarks, designs, secret formulas, equipment and information, and managerial, technical or consultancy services. If rights or services are effectively connected with a permanent establishment or fixed base in the source State, rules for business profits or independent personal services apply. Special-relationship pricing limits treaty application to arm's-length amounts.
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