Withholding on royalties and technical fees permitted at source, subject to treaty limits and permanent establishment exceptions. Taxation of royalties and fees for technical or professional services permits residence taxation of receipts and source taxation of payments arising in a Contracting State subject to a treaty ceiling for beneficial owners resident in the other State; royalties and fees are defined by reference to use of intellectual property, equipment, information and provision of managerial, technical, consultancy or independent professional services. Where the beneficial owner has a permanent establishment in the source State and the rights or services are effectively connected thereto, business profits rules govern. Deemed source rules and arm's length adjustments determine taxable 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.
Withholding on royalties and technical fees permitted at source, subject to treaty limits and permanent establishment exceptions.
Taxation of royalties and fees for technical or professional services permits residence taxation of receipts and source taxation of payments arising in a Contracting State subject to a treaty ceiling for beneficial owners resident in the other State; royalties and fees are defined by reference to use of intellectual property, equipment, information and provision of managerial, technical, consultancy or independent professional services. Where the beneficial owner has a permanent establishment in the source State and the rights or services are effectively connected thereto, business profits rules govern. Deemed source rules and arm's length adjustments determine taxable amounts.
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