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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Royalties and Technical Service Fees Taxed in Both States, Capped at 30% if Beneficial Owner</h1> Royalties and fees for technical services originating in one Contracting State and paid to a resident of the other may be taxed in both states. However, if the recipient is the beneficial owner, the tax in the source state is capped at 30% of the gross amount. 'Royalties' include payments for the use of intellectual property and equipment, while 'fees for technical services' cover managerial, technical, or consultancy services. Exceptions apply if the recipient has a permanent establishment or fixed base in the source state. Payments exceeding fair value due to special relationships are taxed according to each state's laws.
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