https://www.taxtmi.com/acts?id=5967 Royalties under the Thailand DTAA may be taxed in the recipient's State, while the State of source may also tax such royalties subject to a withholding tax cap. The Article defines royalties broadly to include payments for the use or right to use intellectual property, industrial equipment, and technical information. If the recipient carries on business through a permanent establishment or fixed base and the royalties are effectively connected to it, domestic business or service provisions apply instead. The Article also deems source based on the payer or its permanent establishment and requires adjustment for related-party overpricing. en-us Sat, 19 Jan 2008 22:45:54 +0530 Fri, 06 Mar 2009 16:42:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=5967 Royalties under the Thailand DTAA may be taxed in the recipient's State, while the State of source may also tax such royalties subject to a withholding tax cap. The Article defines royalties broadly to include payments for the use or right to use intellectual property, industrial equipment, and technical information. If the recipient carries on business through a permanent establishment or fixed base and the royalties are effectively connected to it, domestic business or service provisions apply instead. The Article also deems source based on the payer or its permanent establishment and requires adjustment for related-party overpricing. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=5967