Royalties and fees for technical services may be taxed in the source State, with limited withholding for beneficial owners. Royalties and fees for technical services arising in a Contracting State may be taxed in the recipient's State and also in the source State subject to a limited withholding where the recipient is the beneficial owner. The Article defines royalties and fees for technical services, excludes services covered by other Articles, limits the withholding where the beneficial owner is not effectively connected to a permanent establishment or fixed base in the source State, deems source where the payer or relevant permanent establishment is located, and treats payments exceeding arm's length amounts as taxable only to the arm's length portion under this Article.
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 fees for technical services may be taxed in the source State, with limited withholding for beneficial owners.
Royalties and fees for technical services arising in a Contracting State may be taxed in the recipient's State and also in the source State subject to a limited withholding where the recipient is the beneficial owner. The Article defines royalties and fees for technical services, excludes services covered by other Articles, limits the withholding where the beneficial owner is not effectively connected to a permanent establishment or fixed base in the source State, deems source where the payer or relevant permanent establishment is located, and treats payments exceeding arm's length amounts as taxable only to the arm's length portion under this Article.
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