https://www.taxtmi.com/acts?id=10377 under the Montenegro DTAA may be taxed in the recipient's State of residence and also in the source State with a limited withholding tax when the beneficial owner is resident in the other Contracting State; competent authorities determine application. "" includes payments for use of copyrights, industrial property, equipment and technical information. The limitation does not apply when royalties are effectively connected to a permanent establishment or fixed base in the source State, in which case rules on business profits or independent personal services apply. are sourced to the payer's residence or to the State of the payer's permanent establishment when borne by it. Special relationships require arm's-length adjustment, leaving excess amounts taxable under domestic law. en-us Sat, 17 Jan 2009 19:00:19 +0530 Mon, 25 Nov 2024 18:10:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=10377 under the Montenegro DTAA may be taxed in the recipient's State of residence and also in the source State with a limited withholding tax when the beneficial owner is resident in the other Contracting State; competent authorities determine application. "" includes payments for use of copyrights, industrial property, equipment and technical information. The limitation does not apply when royalties are effectively connected to a permanent establishment or fixed base in the source State, in which case rules on business profits or independent personal services apply. are sourced to the payer's residence or to the State of the payer's permanent establishment when borne by it. Special relationships require arm's-length adjustment, leaving excess amounts taxable under domestic law. Act-Rules DTAA Sat, 17 Jan 2009 19:00:19 +0530 https://www.taxtmi.com/acts?id=10377