Taxation of royalties and technical services permits source taxation with a capped withholding tax and PE exceptions. Taxation of cross border royalties and fees for technical services may occur in the recipient's State, and also in the source State where payments arise, subject to a withholding cap when the recipient is the beneficial owner. Definitions cover payments for use of intellectual property, equipment, information, and services of managerial, technical or consultancy nature, excluding employee remuneration and certain independent services. Payments connected with a permanent establishment or fixed base are taxed under business profits or independent personal services rules, and special relationship excesses are limited 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.
Taxation of royalties and technical services permits source taxation with a capped withholding tax and PE exceptions.
Taxation of cross border royalties and fees for technical services may occur in the recipient's State, and also in the source State where payments arise, subject to a withholding cap when the recipient is the beneficial owner. Definitions cover payments for use of intellectual property, equipment, information, and services of managerial, technical or consultancy nature, excluding employee remuneration and certain independent services. Payments connected with a permanent establishment or fixed base are taxed under business profits or independent personal services rules, and special relationship excesses are limited to arm's length amounts.
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