Royalties and technical services taxation: source state withholding limited where recipient is beneficial owner, with PE connection exceptions. Payments constituting royalties or fees for technical services arising in one Contracting State and paid to a resident of the other may be taxed in the recipient's State, while the source State may also tax them under its laws subject to a reduced withholding ceiling when the recipient is the beneficial owner. Definitions specify scope of royalties and technical services, and source, permanent establishment/fixed base connection, and special relationship adjustments determine when alternative Articles or arm's length principles apply.
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 services taxation: source state withholding limited where recipient is beneficial owner, with PE connection exceptions.
Payments constituting royalties or fees for technical services arising in one Contracting State and paid to a resident of the other may be taxed in the recipient's State, while the source State may also tax them under its laws subject to a reduced withholding ceiling when the recipient is the beneficial owner. Definitions specify scope of royalties and technical services, and source, permanent establishment/fixed base connection, and special relationship adjustments determine when alternative Articles or arm's length principles apply.
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