Royalties and fees for technical services: source state may tax, subject to residence protections and sourcing rules. Royalties and fees for technical services paid to a resident of the other Contracting State may be taxed in that resident State, and may also be taxed in the source State subject to a maximum tax where the beneficial owner is resident in the other State. Royalties cover payments for use or rights to intellectual property, equipment or technical information; fees for technical services cover managerial, technical or consultancy services and provision of personnel. Payments effectively connected to a permanent establishment or fixed base are taxed under other Articles, and only the arm's-length amount is covered when related-party pricing exceeds market value.
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 fees for technical services: source state may tax, subject to residence protections and sourcing rules.
Royalties and fees for technical services paid to a resident of the other Contracting State may be taxed in that resident State, and may also be taxed in the source State subject to a maximum tax where the beneficial owner is resident in the other State. Royalties cover payments for use or rights to intellectual property, equipment or technical information; fees for technical services cover managerial, technical or consultancy services and provision of personnel. Payments effectively connected to a permanent establishment or fixed base are taxed under other Articles, and only the arm's-length amount is covered when related-party pricing exceeds market value.
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