Taxation of royalties and technical service fees: source state may tax with limited withholding when recipient is beneficial owner. Royalties and fees for technical services arising in a Contracting State may be taxed in the recipient's State of residence but may also be taxed in the source State; if the recipient is the beneficial owner the source tax shall not exceed specified percentages of the gross amount. 'Royalties' includes payments for use of copyrights, patents, trademarks, designs, models, plans, secret formulas or processes, equipment, and technical information. 'Fees for technical services' means payments (other than to employees) for managerial, technical or consultancy services, including provision of personnel. The withholding limits do not apply where the beneficial owner has a permanent establishment or fixed base in the source State and the payments are effectively connected with that establishment.
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 service fees: source state may tax with limited withholding when recipient is beneficial owner.
Royalties and fees for technical services arising in a Contracting State may be taxed in the recipient's State of residence but may also be taxed in the source State; if the recipient is the beneficial owner the source tax shall not exceed specified percentages of the gross amount. "Royalties" includes payments for use of copyrights, patents, trademarks, designs, models, plans, secret formulas or processes, equipment, and technical information. "Fees for technical services" means payments (other than to employees) for managerial, technical or consultancy services, including provision of personnel. The withholding limits do not apply where the beneficial owner has a permanent establishment or fixed base in the source State and the payments are effectively connected with that establishment.
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