The following tax treaty income characterisation issues were identified by the OECD working party dedicated to this matter:
- Business profits and payments for the use of, or the right to use, a copyright.
- Business profits and payments for know-how.
- Business profits and payments for the use of, or the right to use, industrial, commercial or scientific equipment.
- Provision of services.
- Technical fees.
- Mixed payments.
For further information regarding each of the categories above please refer to the links below.
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