Royalties and fees for technical services

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..... es may also be taxed in the Contracting State in which they arise and according to the laws of that State, but the tax so charged shall not exceed : (a) in the case of royalties within sub-paragraph (a) of paragraph 3, and fees for technical services within sub-paragraphs (a) and (c) of paragraph 4 ; (i) during the years 1997 to 2001 : (aa) 15 per cent of the gross amount of such royalties or f .....

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..... ght to use, any copyright of a literary, artistic or scientific work, including cinematograph films or work on film, tape or otherwise means of reproduction for use in connection with radio or television broadcasting, any patent, trade-mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience; and (b) payments of any kind .....

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..... for which a payment described in sub-paragraph (b) of paragraph 3 is received; or (c) make available technical knowledge, experience, skill, know-how or processes, or consist of the development and transfer of a technical plan or technical design. 5. The definitions of fees for technical services in paragraph 4 shall not include amounts paid : (a) for services that are ancillary and subsidiary, .....

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..... State carries on business in the other Contracting State in which the royalties or fees for technical services arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right, property or contract in respect of which the royalties or fees for technical services are paid is effectively connect .....

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..... tate in which the permanent establishment or fixed base is situated. 8. Where, by reason of a special relationship between the payer and the recipient or between both of them and some other person, the amount of the royalties or fees for technical services exceeds, for whatever reason, the amount which would have been paid in the absence of such relationship, the provisions of this article shall .....

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