TaxTMI 
TaxTMI 
Royalties and fees for included services
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....ded services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the beneficial owner of the royalties and fees for included services is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount. The competent authorities of the Contracting States shall by mutual agreement settle the mod....
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.... person in consideration of the rendering of any technical or consultancy services (including through the provisions of services of technical or other personnel) if such services: a) Are ancillary and subsidiary to the application or enjoyment of the right, property or information for which a payment described in paragraph 3 is received; or b) Make available technical knowledge, ....
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....nt; e) To an employee of the person making the payments or to any individual or firm of individuals (other than a company) for professional services as defined in article 14; f) For services rendered in connection with an installation or structure used for the exploration or exploitation of natural resources referred to in paragraph 2, f), of article 5; g) For services r....
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....d to arise in a Contracting State where the payer is that State itself, a political or administrative subdivision thereof, a local authority or a resident of that State. Where, however, the person paying the royalties and fees for included services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or fixed base in connection with which th....