Royalties and technical service fees: source taxation allowed but capped, with PE connections taxed as business income. Royalties and fees for technical services arising in one Contracting State and paid to a resident of the other State may be taxed in the residence State, while the source State may also tax them under its laws subject to a maximum withholding rate when the beneficial owner is a resident of the other State. Payments connected with a permanent establishment or fixed base, or those attributable to business or independent personal services performed from such a base, are taxed under the provisions for business profits or independent personal services. Special-relationship adjustments limit treaty application to arm's-length amounts.
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: source taxation allowed but capped, with PE connections taxed as business income.
Royalties and fees for technical services arising in one Contracting State and paid to a resident of the other State may be taxed in the residence State, while the source State may also tax them under its laws subject to a maximum withholding rate when the beneficial owner is a resident of the other State. Payments connected with a permanent establishment or fixed base, or those attributable to business or independent personal services performed from such a base, are taxed under the provisions for business profits or independent personal services. Special-relationship adjustments limit treaty application to arm's-length amounts.
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