Royalty definition expanded to include payments for technical assistance related to use or rights in property.

The protocol expands the definition of royalty to include payments for technical assistance related to the use of, or the right to use, the property covered by the royalties provision, and clarifies that the non-discrimination clause does not prevent a State from taxing the profits of a permanent establishment of the other State at a higher rate than that imposed on similar domestic companies, nor does it conflict with rules allocating profits to permanent establishments.

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