Technical fees may be taxed in the source state with limited withholding where the recipient is beneficial owner. Technical fees paid or arising in one Contracting State to a resident of the other may be taxed in both States, but if the recipient is the beneficial owner a limited withholding on the gross amount applies. The term covers payments for technical, managerial or consultancy services made to persons other than employees. Fees effectively connected with a permanent establishment or independent personal services in the source State fall outside this Article and are taxed under business profits or independent services rules.
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.
Technical fees may be taxed in the source state with limited withholding where the recipient is beneficial owner.
Technical fees paid or arising in one Contracting State to a resident of the other may be taxed in both States, but if the recipient is the beneficial owner a limited withholding on the gross amount applies. The term covers payments for technical, managerial or consultancy services made to persons other than employees. Fees effectively connected with a permanent establishment or independent personal services in the source State fall outside this Article and are taxed under business profits or independent services rules.
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