ROYALTIES AND FEES FOR TECHNICAL SERVICES. 1. Royalties or 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, such royalties or fees for technical 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 or 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 royalties or fees for technical services. 3. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. The term “fees for technical services” means payments of any kind received as a consideration for the rendering of any managerial, technical or consultancy services, including the provision of technical services by an enterprise or other personnel.
Appears in 1 contract
ROYALTIES AND FEES FOR TECHNICAL SERVICES. 1. Royalties or and 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, such royalties or and fees for technical services may also be taxed in the Contracting State in which they arise arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties or 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 such royalties or fees for technical services, as the case may be.
3. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work work, (including cinematograph films, or and films or tapes used for radio or television broadcasting), any patent, trade mark▇▇▇▇, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience.
4. The term “"fees for technical services” " as used in this Article means payments of any kind received as a to any person, other than payments to an employee of the person making the payments, in consideration for the rendering any services of any a managerial, technical or consultancy services, including the provision of technical services by an enterprise or other personnelnature.
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Sources: Income Tax Agreement
ROYALTIES AND FEES FOR TECHNICAL SERVICES. 1. Royalties or 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, such royalties or fees for technical services 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 royalties or fees for technical services is a resident of the other Contracting State, State the tax so charged shall not exceed 10 per cent of the gross amount of the royalties or fees for technical services.
3. (a) The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, films or films or tapes used for television or radio or television broadcasting, any patent, trade mark▇▇▇▇, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience. The term “fees for technical services” means payments of any kind received as a consideration for the rendering of any managerial, technical or consultancy services, including the provision of technical services by an enterprise or other personnel.
Appears in 1 contract
ROYALTIES AND FEES FOR TECHNICAL SERVICES. 1. Royalties or 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, such royalties or fees for technical 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 or 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 royalties or fees for technical services.
3. (a) The term "“royalties" ” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films and films or tapes used for television or radio or television broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or for the use of, or the right to use, any industrial, commercial or scientific equipment, equipment or for information concerning industrial, commercial or scientific experience. The term “fees for technical services” means payments of any kind received as a consideration for the rendering of any managerial, technical or consultancy services, including the provision of technical services by an enterprise or other personnel.
Appears in 1 contract
ROYALTIES AND FEES FOR TECHNICAL SERVICES. 1. Royalties or and 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, such royalties or and fees for technical services may also be taxed in the Contracting State in which they arise arise, and according to the laws of that State, but if the recipient is the beneficial owner of the royalties or of fees for technical services is a resident of the other Contracting Stateservices, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties or fees for technical services.
3. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or films or tapes used for radio or television broadcasting, any patent, trade mark, design or model, plan, secret formula or process, process or for the use of, or the right to use, industrial, commercial or scientific equipment, equipment or for information concerning industrial, commercial or scientific experience. The term “fees for technical services” means payments of any kind received as a consideration for the rendering of any managerial, technical or consultancy services, including the provision of technical services by an enterprise or other personnel.
Appears in 1 contract
ROYALTIES AND FEES FOR TECHNICAL SERVICES. 1. Royalties or 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 Contracting State.
2. However, such royalties or fees for technical services may also be taxed in the Contracting State in which they arise arise, and according to the laws of that Contracting State, but if the recipient is the beneficial owner of the royalties or fees for technical services is a resident of the other Contracting Stateservices, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties or fees for technical services.
3. The term "“royalties" ” as used in this Article means payments payment of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or cinematography films and films or tapes used for radio or television broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience.
4. The term “fees for technical services” as used in this Article means payments of any kind received as a consideration payment for the rendering provision of any services of managerial, technical or consultancy servicesnature by a resident of a Contracting State in the other Contracting State, including the provision of technical services by an enterprise or other personnel.but does not
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Sources: Tax Treaty