Royalties and technical service fees: source-state taxation permitted, treaty withholding cap applies 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, while the source State may also tax them subject to a treaty withholding cap where the recipient is the beneficial owner. 'Royalties' includes payments for use of intellectual property, equipment, or technical information; 'fees for technical services' include managerial, technical, or consultancy services, excluding services covered by other treaty Articles. Exceptions apply where payments are effectively connected with a permanent establishment or fixed base, and related-party excesses are limited to arm's-length amounts.
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-state taxation permitted, treaty withholding cap applies 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, while the source State may also tax them subject to a treaty withholding cap where the recipient is the beneficial owner. "Royalties" includes payments for use of intellectual property, equipment, or technical information; "fees for technical services" include managerial, technical, or consultancy services, excluding services covered by other treaty Articles. Exceptions apply where payments are effectively connected with a permanent establishment or fixed base, and related-party excesses are limited to arm's-length amounts.
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