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 ... Summary
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.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.