Royalties and technical service fees can be taxed by the payer's state, with source tax capped at 10% for beneficial owners. Royalties and fees for technical services paid to a resident of the other Contracting State may be taxed in the recipient's State and also in the source State, but where the beneficial owner is resident of the other State the source State's tax is limited to 10 per cent of the gross amount. Definitions cover payments for use or rights in intellectual property and for managerial, technical or consultancy services (excluding Articles 14 and 15). Payments are sourced to the payer's State or to the State of a permanent establishment or fixed base that incurred the liability, and payments effectively connected to such establishment or base fall under Articles 7 or 14. Special-relationship adjustments limit treaty benefits to arm's length amounts; excesses remain taxable under domestic law.
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 can be taxed by the payer's state, with source tax capped at 10% for beneficial owners.
Royalties and fees for technical services paid to a resident of the other Contracting State may be taxed in the recipient's State and also in the source State, but where the beneficial owner is resident of the other State the source State's tax is limited to 10 per cent of the gross amount. Definitions cover payments for use or rights in intellectual property and for managerial, technical or consultancy services (excluding Articles 14 and 15). Payments are sourced to the payer's State or to the State of a permanent establishment or fixed base that incurred the liability, and payments effectively connected to such establishment or base fall under Articles 7 or 14. Special-relationship adjustments limit treaty benefits to arm's length amounts; excesses remain taxable under domestic law.
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