Royalties taxability: source-state may tax royalties; definition covers payments for use or right to use IP and technical information. Royalties arising in a Contracting State may be taxed there; 'royalties' means payments for the use of, or the right to use, intellectual property (copyrights, patents, trade marks, designs, plans, secret formulas or processes), for use of industrial, commercial or scientific equipment, and for information concerning industrial, commercial or scientific experience; rentals and income relating to cinematographic films are excluded and treated as business profits.
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 taxability: source-state may tax royalties; definition covers payments for use or right to use IP and technical information.
Royalties arising in a Contracting State may be taxed there; "royalties" means payments for the use of, or the right to use, intellectual property (copyrights, patents, trade marks, designs, plans, secret formulas or processes), for use of industrial, commercial or scientific equipment, and for information concerning industrial, commercial or scientific experience; rentals and income relating to cinematographic films are excluded and treated as business profits.
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