Royalties and fees for technical services: source-state taxation allowed with capped rate and permanent establishment exception. Article allocates taxation of royalties and fees for technical services between source and residence: such payments may be taxed in the recipient's residence and may also be taxed in the source State subject to a capped source-State tax when the beneficial owner is resident elsewhere. Definitions specify covered payments for use of intellectual property and for managerial, technical or consultancy services. Payments effectively connected with a permanent establishment or fixed base are taxed under the rules for business profits or independent personal services. Special-relationship pricing is adjusted to arm's-length amounts, with excess taxable under domestic law.
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 taxation allowed with capped rate and permanent establishment exception.
Article allocates taxation of royalties and fees for technical services between source and residence: such payments may be taxed in the recipient's residence and may also be taxed in the source State subject to a capped source-State tax when the beneficial owner is resident elsewhere. Definitions specify covered payments for use of intellectual property and for managerial, technical or consultancy services. Payments effectively connected with a permanent establishment or fixed base are taxed under the rules for business profits or independent personal services. Special-relationship pricing is adjusted to arm's-length amounts, with excess taxable under domestic law.
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