Taxation of royalties: source state retains exclusive taxing right over royalties paid to non-residents under treaty rules. Article 13 grants the source state exclusive taxation of royalties paid to residents of the other Contracting State; it provides a broad definition of royalties covering payments for use of intellectual property, equipment and technical information while excluding amounts related to extraction operations. Cinematographic film receipts are taxable only in the source state under its laws. Founders' shares issued in the United Arab Republic as consideration for listed rights and taxed under the specified domestic law fall outside this article, and a royalty is deemed to arise where the payer is the state, a political subdivision, a local authority or a resident.
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.
Taxation of royalties: source state retains exclusive taxing right over royalties paid to non-residents under treaty rules.
Article 13 grants the source state exclusive taxation of royalties paid to residents of the other Contracting State; it provides a broad definition of royalties covering payments for use of intellectual property, equipment and technical information while excluding amounts related to extraction operations. Cinematographic film receipts are taxable only in the source state under its laws. Founders' shares issued in the United Arab Republic as consideration for listed rights and taxed under the specified domestic law fall outside this article, and a royalty is deemed to arise where the payer is the state, a political subdivision, a local authority or a resident.
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