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TMI BlogRoyalties and fees for technical servicesX X X X Extracts X X X X X X X X Extracts X X X X ..... ntracting State in which they arise and according to the law of that State, but if the recipient is the beneficial owner of the royalties or fees for technical services, the tax so charged shall not exceed ten per cent of the gross amount of 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 o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... services of technical or other personnel. 5. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties or fees for technical services, being a resident of a Contracting 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 othe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he royalties or fees for technical services was incurred, and such royalties or fees for technical services are borne by such permanent establishment or fixed base, then such royalties or fees for technical services shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. 7. Where, by reason of a special relationship between the payer and the beneficial ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t is the beneficial owner of the royalties or fees for technical services the tax so charged shall not exceed : (i) in the case of royalties relating to the payments for the use of, or the right to use, industrial, commercial or scientific equipment, 10 per cent of the gross amount of the royalties; (ii) in the case of fees for technical services and other royalties, 20 per cent of the gross amoun ..... X X X X Extracts X X X X X X X X Extracts X X X X
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