ROYALTIES AND FEES FOR TECHNICAL SERVICES. 1. Royalties 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.
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.
ROYALTIES AND FEES FOR TECHNICAL SERVICES. 1. Royalties 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[2. However, such royalties and 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, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties or the fees for technical services.]
ROYALTIES AND FEES FOR TECHNICAL SERVICES. 1. Royalties and fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may 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 of the fees for technical services the tax so charged shall not exceed: (a) in the case of royalties as defined in paragraph 2 sub- paragraph (a) 15% of the gross amount of such royalties; (b) in the case of royalties as defined in paragraph 2 sub- paragraph (b) 10% of the gross amount of such royalties; and (c) in the case of fees for technical services 7.5% of the gross amount of such fees.
