Royalties taxation: source state may tax royalties with a capped withholding where recipient is the beneficial owner. Royalties paid to a resident of the other Contracting State may be taxed in the recipient's State, while source State taxation is permitted but limited to ten percent of the gross amount when the recipient is the beneficial owner. The Article broadly defines royalties to include copyrights, patents, trademarks, know how, computer software and information, and provides that where rights are effectively connected to a permanent establishment or fixed base the rules for business profits or independent personal services apply instead.
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 taxation: source state may tax royalties with a capped withholding where recipient is the beneficial owner.
Royalties paid to a resident of the other Contracting State may be taxed in the recipient's State, while source State taxation is permitted but limited to ten percent of the gross amount when the recipient is the beneficial owner. The Article broadly defines royalties to include copyrights, patents, trademarks, know how, computer software and information, and provides that where rights are effectively connected to a permanent establishment or fixed base the rules for business profits or independent personal services apply instead.
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