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Royalties and fees for technical services

Article 12 - Agreements - Kazakstan - Article 12 - Article 12 : 1. Royalties or fee 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. However, such royalti .....

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d 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 us .....

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and payments for the use of, or the right to use, industrial, commercial or scientific equipment. (b) The term "fees for technical services" means payment of any kind in consideration for the rendering of any managerial, technical or consu .....

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al owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other State independent perso .....

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the case may be, shall apply. 5. 1[Royalties or fees for technical services shall be deemed to arise in a Contracting State when the payer is a resident of that Contracting State.] Where, however, the person paying the royalties or fees for technica .....

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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 .....

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