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Article 12 - ROYALTIES AND FEES FOR TECHNICAL SERVICES - Republic of Korea [South Korea]

Extract

..... the tax so charged shall not exceed 10 per cent of the gross amount of the royalties or fees for technical services. 3. a) The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films or films or tapes used for television or radio broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or for the .....

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Article 12 - ROYALTIES AND FEES FOR TECHNICAL SERVICES - Republic of Korea South Korea

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..... is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 5. Royalties and fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political sub-division, a local authority, or a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of a Contracting State or no .....

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Article 12 - ROYALTIES AND FEES FOR TECHNICAL SERVICES - Republic of Korea South Korea

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