TECHNICAL FEES. 1. Technical fees derived from one of the Contracting 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 the first-mentioned Contracting State at a rate not exceeding 10 per cent of the gross amount of the technical fees.
2. The term " technical fees " as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature.
3. The provisions of paragraph 1 of this Article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, or performs in that other State independent personal services, and the technical fees are effectively connected with such permanent establishment or such services. In such case, the provisions of Article 7 or Article 15, as the case may be, shall apply.
4. Technical fees shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority thereof, or a resident of that State. Where, however, the person paying the technical fees, whether he is a resident of the Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated.
5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other persons, the amount of the technical fees paid exceeds, for what ever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.
TECHNICAL FEES. 1. Technical fees arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State.
TECHNICAL FEES. Technical fees arising in one of the States and paid to a resident of the other State may be taxed in that other State.
TECHNICAL FEES. 1) Technical fees derived by a resident of a Contracting State in respect of activities of a technical, managerial or consultancy cha- racter shall be taxable only in that State.
2) However, if such activities are exercised in the other Contracting State, such techni- cal fees as are derived therefrom may be taxed in that other State but the tax so charged shall not exceed 10 % of the gross amount of the technical fees.
3) The term "technical fees" as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments or to a person mentioned in Article 16, in consideration for any services of a technical, managerial or consultancy nature.
4) The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, exercises the activities dealt with in paragraph 1 in the other Contracting State through a permanent es- tablishment situated therein. In such a case the provisions of Article 7 shall apply.
5) Notwithstanding the provisions of para- graph 2, the beneficial owner of the tech- nical fees may choose to be taxed as if the activities giving rise to the technical fees exercised in the other Contracting State were exercised through a permanent esta- blishment situated in the other Contracting State.
6) Where, by reason of a special relations- hip between the payer and the beneficial owner or between both of them and some other person, the amount of the technical fees paid exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Convention.
TECHNICAL FEES. 1. 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 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 technical 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 technical fees. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation.
3. The term “technical fees” as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any service of a technical, managerial or consultancy nature, unless the payment is limited to the reimbursement of actual expenses incurred by that person with respect to the service.
4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise, through a permanent establishment situated therein and the technical fees are effectively connected with such permanent establishment. In such case, the provisions of Article 7 shall apply.
5. Technical fees shall be deemed to arise in a Contracting State when the payer is a resident of that State. Where, however, the person paying the technical fees, whether that person is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by the permanent establishment, then such technical fees shall be deemed to arise in the State in which the permanent establishment is situated.
6. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the technical fees paid exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.
TECHNICAL FEES. 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, fees for technical services arising in a Contracting State may also be taxed in the Contracting State in which they arise and subject 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.
TECHNICAL FEES. 1. Technical fees arising in a Contracting State which are derived by a resident of the other Contracting State may be taxed in that other State.
2. However, such technical fees may also be taxed in the Contracting State in which they arise, and according to the law of that State; but where such technical fees are derived by a resident of the other Contracting State who is subject to tax in that State in respect thereof, the tax charged in the Contracting State in which the technical fees arise shall not exceed 10 percent of the gross amount of such fees.
3. The term “technical fees” as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of an administrative, technical, managerial or consultancy nature.
4. The provisions of paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the technical fees, being resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the technical fees are effectively connected with such permanent establishment or fixed base. In such a case, the provisions of Articles 7 or 14, as the case may be, shall apply.
5. Technical fees shall be deemed to arise in a Contracting State when the payer is that State, a political subdivision, a local authority or a resident of that State. Where, however, the person paying the technical fees, whether he is resident of a Contracting State or not, has in a Contracting State a permanent establishment or fixed base in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by that permanent establishment or fixed base, then such technical fees shall be deemed to arise in the State in which the permanent establishment or fixed base is situated.
6. Where by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the technical fees paid exceeds, for whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable accor...
TECHNICAL FEES. Technical Fees" means as all payments received by Customer for the Treatment Services being provided using the Accuray Deliverables, excluding the "professional" services collected for the physician surgeons and radiation oncologists administering or prescribing the treatment (such professional services fees, "Professional Fee"). Revenue Share payments are due for the Term of this Agreement. Revenue Share Payments are net of Customer's Minimum Monthly Payments, i.e., the month when the collections were received. If the Revenue Share Payment due to Accuray in any given month is less than the Minimum Monthly Payment, then Customer shall pay the Minimum Monthly Payment in that month only.
TECHNICAL FEES. Technical Fees" shall be defined as all payments received by Institution for the Treatment Services being provided on the Equipment, excluding the "professional" services collected for the physician surgeons and radiation oncologists administering or prescribing the treatment ("Professional Fee").
TECHNICAL FEES. For the avoidance of doubt, technical fees received as part of a global payment in all cases shall be retained by Company.
