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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Article 12 limits royalty and technical service fee tax to 10 percent and applies arm's-length source pricing rules</h1> Article 12 allocates taxing rights over royalties and fees for technical services between the two Contracting States. Such income may be taxed in the recipient's State of residence, but the source State may also tax it, capped at 10 percent of the gross amount where the beneficial owner is resident in the other State. Royalties cover consideration for use of intellectual property, equipment, or know-how; fees for technical services cover managerial, technical, or consultancy services, including personnel. Business profits rules apply where the income is effectively connected with a permanent establishment or fixed base. Detailed source rules deem where royalties and fees arise, and transfer-pricing style rules limit treaty benefits where payments exceed arm's-length amounts.
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