ROYALTIES AND FEES FOR TECHNICAL SERVICES. 1. Royalties and 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, such royalties and technical fees 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 or of the technical fees is a resident of the other Contracting State, the tax so charged shall not exceed: a) In the case of technical fees 7.5 per cent of the gross amount of the fees; b) In the case of royalties:
Appears in 3 contracts
Samples: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
ROYALTIES AND FEES FOR TECHNICAL SERVICES. 1. Royalties and fees for technical fees services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State.
2] 2[2. However, such royalties and fees for technical fees services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties royalties, or of the fees for technical fees is a resident of the other Contracting Stateservices, the tax so charged shall not exceed:
a) In the case of technical fees 7.5 exceed 10 per cent of the gross amount of the fees;
b) In royalties or the case of royalties:fees for technical services.]
Appears in 2 contracts
Samples: Agreement for Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
