Royalties and fees for technical services: source-state may tax with capped rate when recipient is beneficial owner. 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 of residence, but may also be taxed in the source State; where the recipient is the beneficial owner, source-state tax is limited. Royalties include payments for use or rights to intellectual property, equipment use and technical information. Fees for technical services cover managerial, technical and consultancy services and services by technical personnel, excluding services covered elsewhere in the Convention.
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 fees for technical services: source-state may tax with capped rate when recipient is beneficial owner.
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 of residence, but may also be taxed in the source State; where the recipient is the beneficial owner, source-state tax is limited. Royalties include payments for use or rights to intellectual property, equipment use and technical information. Fees for technical services cover managerial, technical and consultancy services and services by technical personnel, excluding services covered elsewhere in the Convention.
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