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, ... Summary
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.
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