Royalties and technical service payments: subject to source taxation with limited withholding where the recipient is the beneficial owner. Article 13 permits source state taxation of royalties, fees for technical services and payments for use of equipment paid to residents of the other Contracting State, with a reduced withholding when the recipient is the beneficial owner. It defines royalties, technical service fees and equipment payments, excludes payments attributable to employment or specified independent services, and disapplies the Article where the income is effectively connected with a permanent establishment or fixed base. Special relationships that inflate payments are limited to arm's length amounts.
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 technical service payments: subject to source taxation with limited withholding where the recipient is the beneficial owner.
Article 13 permits source state taxation of royalties, fees for technical services and payments for use of equipment paid to residents of the other Contracting State, with a reduced withholding when the recipient is the beneficial owner. It defines royalties, technical service fees and equipment payments, excludes payments attributable to employment or specified independent services, and disapplies the Article where the income is effectively connected with a permanent establishment or fixed base. Special relationships that inflate payments are limited to arm's length amounts.
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