Royalties and fees for technical services may be taxed in source state, with tax limited where recipient is beneficial owner. Royalties and fees for technical services arising in one Contracting State may be taxed in that State, but if paid to the beneficial owner residing in the other State the source State's tax is capped. 'Royalties' covers payments for rights to use copyrights, patents, trademarks, designs, plans, formulas, processes, equipment or technical information; 'fees for technical services' covers managerial, technical or consultancy services including personnel services. If the beneficial owner has a permanent establishment or fixed base in the source State and the rights are effectively connected there, rules on business profits or independent personal services apply instead.
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 may be taxed in source state, with tax limited where recipient is beneficial owner.
Royalties and fees for technical services arising in one Contracting State may be taxed in that State, but if paid to the beneficial owner residing in the other State the source State's tax is capped. "Royalties" covers payments for rights to use copyrights, patents, trademarks, designs, plans, formulas, processes, equipment or technical information; "fees for technical services" covers managerial, technical or consultancy services including personnel services. If the beneficial owner has a permanent establishment or fixed base in the source State and the rights are effectively connected there, rules on business profits or independent personal services apply instead.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
TaxTMI 
