Royalties and technical service fees: source taxation allowed, reduced withholding for the beneficial owner and PE connection rules apply. Royalties and fees for technical services arising in one Contracting State and paid to a resident of the other may be taxed in the recipient's State; the source State may also tax them but source tax on such payments to the beneficial owner is limited. The Article defines royalties and fees for technical services, lists specific exclusions, provides that effective connection with a permanent establishment or fixed base shifts taxation to Articles 7 or 14, and requires arm's length adjustment where related party arrangements inflate payments.
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: source taxation allowed, reduced withholding for the beneficial owner and PE connection rules apply.
Royalties and fees for technical services arising in one Contracting State and paid to a resident of the other may be taxed in the recipient's State; the source State may also tax them but source tax on such payments to the beneficial owner is limited. The Article defines royalties and fees for technical services, lists specific exclusions, provides that effective connection with a permanent establishment or fixed base shifts taxation to Articles 7 or 14, and requires arm's length adjustment where related party arrangements inflate payments.
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