FEES FOR TECHNICAL SERVICES. 1. Fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, subject to the provisions of Articles 8, 16 and 17, fees for technical services arising in a Contracting State 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 fees is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the fees.
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Samples: Agreement for the Elimination of Double Taxation, Agreement for the Elimination of Double Taxation
FEES FOR TECHNICAL SERVICES. 1. Fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State.
2. However, notwithstanding the provisions of Article 15 and subject to the provisions provi- sions of Articles 8, 16 17 and 1718, fees for technical services arising in a Contracting State 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 fees is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent percent of the gross amount of the fees.
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FEES FOR TECHNICAL SERVICES. 1. Fees for technical services Technical fees arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State.
2. However, subject to the provisions of Articles 8, 16 and 17, such technical fees for technical services arising in a Contracting State may also be taxed in the Contracting State in which they arise arise, and according to the laws of that State, but if the beneficial owner of the technical fees is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent six (6) percent of the gross amount of the technical fees.
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FEES FOR TECHNICAL SERVICES. 1. Fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State.
2. However, subject to the provisions of Articles 8, 16 and 17, such fees for technical services arising in a Contracting State may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if where the beneficial owner of the fees for technical services is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the fees.a
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FEES FOR TECHNICAL SERVICES. 1. Fees for technical services arising in a derived from one of the Contracting State and paid to States by a resident of the other Contracting State who is the beneficial owner thereof and is subject to tax in that other State in respect thereof may be taxed in that other State.
2. However, subject to the provisions of Articles 8, 16 and 17, fees for technical services arising in a first-mentioned Contracting State 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 fees is at a resident of the other Contracting State, the tax so charged shall rate not exceed 10 exceeding 5 per cent of the gross amount of the such fees.
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