Royalties and technical service fees: source-state taxation permitted, limited by withholding cap when recipient is beneficial owner. Royalties and fees for technical services arising in one Contracting State and paid to a resident of the other may be taxed in the recipient's residence, and may also be taxed in the source State subject to a withholding cap if the recipient is the beneficial owner. 'Royalties' includes payments for use of intellectual property and industrial information; 'fees for technical services' covers managerial, technical or consultative services excluding employee remuneration and certain independent personal services. Payments effectively connected with a permanent establishment or fixed base are taxed under business or independent services provisions.
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 fees: source-state taxation permitted, limited by withholding cap when recipient is beneficial owner.
Royalties and fees for technical services arising in one Contracting State and paid to a resident of the other may be taxed in the recipient's residence, and may also be taxed in the source State subject to a withholding cap if the recipient is the beneficial owner. "Royalties" includes payments for use of intellectual property and industrial information; "fees for technical services" covers managerial, technical or consultative services excluding employee remuneration and certain independent personal services. Payments effectively connected with a permanent establishment or fixed base are taxed under business or independent services provisions.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
