Royalties and fees for technical services: source State may tax but withholding limited to a reduced maximum rate. Royalties and fees for technical services arising in one Contracting State may be taxed in the recipient's State, and may also be taxed in the source State but, if the beneficial owner is resident in the other State, source taxation is limited to a reduced maximum withholding rate. Exceptions apply where the beneficial owner has a permanent establishment or fixed base in the source State and the right or property is effectively connected, in which case rules on business profits or independent personal services govern. Payments deemed to arise where the payer or attributable permanent establishment/fixed base is situated. Special relationships require arm's length adjustment.
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: source State may tax but withholding limited to a reduced maximum rate.
Royalties and fees for technical services arising in one Contracting State may be taxed in the recipient's State, and may also be taxed in the source State but, if the beneficial owner is resident in the other State, source taxation is limited to a reduced maximum withholding rate. Exceptions apply where the beneficial owner has a permanent establishment or fixed base in the source State and the right or property is effectively connected, in which case rules on business profits or independent personal services govern. Payments deemed to arise where the payer or attributable permanent establishment/fixed base is situated. Special relationships require arm's length adjustment.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
