Withholding on royalties and technical service fees limited when recipient is beneficial owner, subject to permanent establishment connection. 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, but the source State may also tax them; where the recipient is the beneficial owner the tax so charged shall not exceed ten per cent of the gross amount. Payments connected with a permanent establishment or fixed base in the source State are governed by Article 7 or Article 15. Related party excess payments are limited to arm's length amounts 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.
Withholding on royalties and technical service fees limited when recipient is beneficial owner, subject to permanent establishment connection.
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, but the source State may also tax them; where the recipient is the beneficial owner the tax so charged shall not exceed ten per cent of the gross amount. Payments connected with a permanent establishment or fixed base in the source State are governed by Article 7 or Article 15. Related party excess payments are limited to arm's length amounts under this Article.
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