Royalties and technical service fees: limited source-state taxation with reduced withholding and permanent establishment exceptions. Article 12 permits residence-state taxation of royalties and fees for technical services but allows the source State to tax amounts arising there, subject to a withholding cap of ten percent where the beneficial owner is resident in the other Contracting State. It defines royalties to include payments for use of copyrights, patents, trademarks, designs, plans, secret formulae, processes, equipment or industrial information, and defines fees for technical services to include managerial, technical or consultancy services including personnel, excluding Articles 14 and 15 services.
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 service fees: limited source-state taxation with reduced withholding and permanent establishment exceptions.
Article 12 permits residence-state taxation of royalties and fees for technical services but allows the source State to tax amounts arising there, subject to a withholding cap of ten percent where the beneficial owner is resident in the other Contracting State. It defines royalties to include payments for use of copyrights, patents, trademarks, designs, plans, secret formulae, processes, equipment or industrial information, and defines fees for technical services to include managerial, technical or consultancy services including personnel, excluding Articles 14 and 15 services.
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