Royalties and technical service fees: source-state taxation may be limited when recipient is beneficial owner. 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 ... Summary
Royalties and technical service fees: source-state taxation may be limited when recipient is beneficial owner.
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 may also be taxed in the source State; where the recipient is the beneficial owner, source-state tax shall not exceed 15 per cent of the gross amount. Definitions clarify "royalties" to include payments for rights to use intellectual property and information, and "fees for technical services" to include managerial, technical or consultancy services. Payments effectively connected to a permanent establishment fall under business profits rules and related-party excess payments are limited to the arm's-length amount for treaty application.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 1
Join Channel
TaxTMI 
