FEES FOR TECHNICAL SERVICES. 1. Fees for technical services 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, subject to the provisions of Articles 8, 16 and 17, 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 7.5 per cent of the gross amount of the fees.
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Sources: Agreement for the Elimination of Double Taxation With Respect to Taxes on Income
FEES FOR TECHNICAL SERVICES. 1. Fees for technical services arising in a Contracting State which are derived by and paid to a resident of the other Contracting State may be taxed in that other State.
2. However, subject to the provisions of Articles 8, 16 and 17, fees for technical services arising in a Contracting State may also be taxed in the Contracting that State in which they arise and subject according 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 7.5 10 per cent of the gross amount of the technical fees.
Appears in 1 contract
FEES FOR TECHNICAL SERVICES. 1. Fees for technical services arising in a Contracting State which are derived by and paid to a resident of the other Contracting State may be taxed in that other State.
2. However, subject to the provisions of Articles 8, 16 and 17, fees for technical services arising in a Contracting State may also be taxed in the Contracting State in which they arise and subject according 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 7.5 5 per cent of the gross amount of the fees.
Appears in 1 contract
Sources: Double Taxation Agreement