Royalties taxation: source-state may tax payments to nonresidents, though withholding is capped for beneficial owners under treaty. Royalties and fees for included 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 on such payments is capped at a specified maximum of the gross amount. The Article defines royalties to include payments for use of intellectual property, equipment, technical information and broadcasting media, and defines fees for included services to include ancillary assistance and technical or consultancy services that transfer technical knowledge or designs.
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 taxation: source-state may tax payments to nonresidents, though withholding is capped for beneficial owners under treaty.
Royalties and fees for included 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 on such payments is capped at a specified maximum of the gross amount. The Article defines royalties to include payments for use of intellectual property, equipment, technical information and broadcasting media, and defines fees for included services to include ancillary assistance and technical or consultancy services that transfer technical knowledge or designs.
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