Royalties and technical service fees: taxable where sourced, subject to a capped withholding tax for non-resident beneficial owners. Royalties and fees for technical services arising in one Contracting State may be taxed in the State of residence of the recipient but may also be taxed in the State of source with a limited withholding where the beneficial owner is resident of the other State. The Article defines royalties and fees for technical services, excludes employee remuneration, deems source by payer residence or by permanent establishment/fixed base connection, and restricts treaty relief where payments exceed arm's-length amounts due to special relationships.
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: taxable where sourced, subject to a capped withholding tax for non-resident beneficial owners.
Royalties and fees for technical services arising in one Contracting State may be taxed in the State of residence of the recipient but may also be taxed in the State of source with a limited withholding where the beneficial owner is resident of the other State. The Article defines royalties and fees for technical services, excludes employee remuneration, deems source by payer residence or by permanent establishment/fixed base connection, and restricts treaty relief where payments exceed arm's-length amounts due to special relationships.
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