Taxation of automated digital services: source-state tax with a negotiated gross-basis cap or election to tax qualified profits. Income from automated digital services arising in a Contracting State may be taxed in the State where it arises subject to a negotiated cap of the gross payments when the beneficial owner is resident in the other Contracting State; alternatively the beneficial owner may elect source-state taxation of its qualified profits, determined by applying a profitability ratio to gross revenue and taking 30 per cent, with multinational group ratios usable where higher and available.
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.
Taxation of automated digital services: source-state tax with a negotiated gross-basis cap or election to tax qualified profits.
Income from automated digital services arising in a Contracting State may be taxed in the State where it arises subject to a negotiated cap of the gross payments when the beneficial owner is resident in the other Contracting State; alternatively the beneficial owner may elect source-state taxation of its qualified profits, determined by applying a profitability ratio to gross revenue and taking 30 per cent, with multinational group ratios usable where higher and available.
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