Royalties taxation caps: source State may tax royalties but limits apply and residence State may also tax. Article 12 permits taxation of royalties by the recipient's State and also by the State of source subject to prescribed limits; it defines royalties to include payments for use or right to use intellectual property, equipment, technical information, films and related services, while excluding certain services linked to sales, rentals for international transport, teaching, personal services, employee remuneration and specified professional services. Royalties connected to a permanent establishment or fixed base are taxed under business profits or independent personal services rules, and amounts inflated by special relationships are limited to arm's length consideration for the Article's purposes.
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 caps: source State may tax royalties but limits apply and residence State may also tax.
Article 12 permits taxation of royalties by the recipient's State and also by the State of source subject to prescribed limits; it defines royalties to include payments for use or right to use intellectual property, equipment, technical information, films and related services, while excluding certain services linked to sales, rentals for international transport, teaching, personal services, employee remuneration and specified professional services. Royalties connected to a permanent establishment or fixed base are taxed under business profits or independent personal services rules, and amounts inflated by special relationships are limited to arm's length consideration for the Article's purposes.
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