Taxation of cross-border royalties and technical service fees: source state may tax, reduced withholding if 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, while the source State may also tax them; if the recipient is the beneficial owner the source State's tax shall not exceed 10 per cent of the gross amount. Definitions delimit 'royalties' and 'fees for technical services,' and the Article gives effect to permanent establishment and fixed base connections so that Article 7 or Article 14 applies when relevant; arm's length principles address related party pricing.
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.
Taxation of cross-border royalties and technical service fees: source state may tax, reduced withholding if 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, while the source State may also tax them; if the recipient is the beneficial owner the source State's tax shall not exceed 10 per cent of the gross amount. Definitions delimit "royalties" and "fees for technical services," and the Article gives effect to permanent establishment and fixed base connections so that Article 7 or Article 14 applies when relevant; arm's length principles address related party pricing.
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