Technical Services Fees in Recent Tax Treaties

Journal
Law, S.B.
International
Bulletin for International Taxation 2010 (Volume 64), No. 5
PriceUSD 45

In this article, the author surveys the various approaches to technical services fees adopted in recently concluded tax treaties. The results suggest that most recent tax treaties contain special rules, beyond those offered by the OECD Model Tax Convention, to allow source states to tax technical services fees.