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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Royalties and technical service fees taxed at 10% if recipient is beneficial owner; exceptions for specific services.</h1> Royalties and fees for technical services arising in one Contracting State and paid to a resident of the other Contracting State may be taxed in the recipient's State, with a maximum tax rate of 10% if the recipient is the beneficial owner. 'Royalties' include payments for the use of intellectual property, while 'fees for technical services' cover payments for technical or consultancy services. Exceptions apply for services linked to property sales, rentals, education, personal use, or employee services. The provisions do not apply if the recipient operates through a permanent establishment in the source State, where other articles govern taxation.
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