Royalties and fees for included services: source State may withhold tax subject to a limited withholding where beneficial owner resides elsewhere. 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, but the source State may also tax such payments subject to a limited withholding if the beneficial owner is resident in the other State; competent authorities will agree the application method. 'Royalties' covers payments for use or rights in intellectual property and related information; 'fees for included services' covers technical or consultancy services that are ancillary to or make available technical knowledge or designs, with specified exclusions and special rules where a permanent establishment or fixed base is involved.
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 included services: source State may withhold tax subject to a limited withholding where beneficial owner resides elsewhere.
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, but the source State may also tax such payments subject to a limited withholding if the beneficial owner is resident in the other State; competent authorities will agree the application method. "Royalties" covers payments for use or rights in intellectual property and related information; "fees for included services" covers technical or consultancy services that are ancillary to or make available technical knowledge or designs, with specified exclusions and special rules where a permanent establishment or fixed base is involved.
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