Royalties and fees for technical services: source-state limited taxation with beneficial owner cap and permanent establishment exception. Royalties and fees for technical services arising in one Contracting State and paid to a resident of the other may be taxed in the recipient's State, ... Summary
Royalties and fees for technical services: source-state limited taxation with beneficial owner cap and permanent establishment exception.
Royalties and fees for technical services arising in one Contracting State and paid to a resident of the other may be taxed in the recipient's State, while the source State may also tax such payments subject to a capped rate when the beneficial owner is resident of the other Contracting State. The Article defines royalties and fees for technical services broadly, excludes its limitation where income is effectively connected to a permanent establishment or fixed base in the source State, deems source of income by payer residence or by the permanent establishment bearing the liability, and requires arm's-length adjustments where special relationships inflate payments.
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