Примеры использования Technical and other services на Английском языке и их переводы на Русский язык
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II. What are technical and other services?
This approach does not deal specifically with income from technical and other services.
Administrative, technical and other services.
For these countries, reduced time thresholds would be appropriate only for technical and other services.
Note on the taxation of fees for technical and other services under the United Nations Model Convention.
Countries have adopted a variety of provisions in their bilateral treaties to deal with income from technical and other services.
This result is problematic from the perspective of some countries because the fees paid to non-residents for technical and other services are ordinarily deductible in computing the income of the person to whom the services are provided.
The necessary changes to articles 5 and 14 would be simple and would not necessitate defining technical and other services.
Article 12(Royalties) does not apply to fees for technical and other services because the definition of royalties in article 12(3) is limited to payments for the use of, or the right to use, intellectual property or equipment or information.
Revise article 12 to include technical and other services.
Some countries may take the position that the existing time thresholds in articles 5(3)(b) and 14(1)(b)are appropriate for services generally but not for technical and other services.
On the other hand,if income from technical and other services is considered to be business profits or income from professional or independent services, it is dealt with in article 7 or article 14 and is not taxable by the source country even if it arises in that country.
IV. Options for dealing with income from technical and other services.
If the time thresholds for the purposes of articles 5(3)(b) and 14(1)(b) were reduced to, say, 90 or 120 days in any 12-month period, source countries would have expanded taxing rights over income from business and professional services, including income from technical and other services.
Such a discussion could be presented in a neutral manner,setting out the arguments for and against including any special provisions dealing with technical and other services in tax treaties, without any suggestion regarding how countries might deal with the issue.
The Unit processes claims for death and disability of contingent members, emplacement, rotation and repatriation of military contingents and contingent-owned equipment, consumable supplies,ammunition and weapons, and for technical and other services.
Thus, arguably, if income from technical and other services is characterized as income, other than business profits or income from professional and other independent services, under the domestic law of the source country, such income is taxable by the source country if it arises in the source country.
In all regions, emerging donors are supporting the expansion of South-South and triangular cooperation and offering a range of financial, technical and other services to other developing countries.
If income from technical and other services is not considered to be income from carrying on business dealt with under article 7 or income from professional or independent personal services dealt with under article 14, such income may be taxable by a source country if the income arises in the source country in accordance with article 21 3.
Assistance to regions and Governments was provided to build emergency-responsecapacity regarding specific emergencies, including the provision of organized technical and other services for response preparedness.
The foregoing brief overview of the provisions of the United Nations Model Convention that are potentially applicable to income from technical and other services shows that it is relatively easy for an enterprise resident in a contracting State to avoid tax on such income in the other contracting State, especially where the services are rendered to a related enterprise in the source country.
Under this approach, not only would the commentary be revised to include a discussion of the issue butit would also go further than the previous approach by including alternative provisions that countries would be encouraged to use if they concluded that technical and other services should be dealt with in their treaties.
Advisory Board members have noted that the establishment of a permanent secretariat in New York would provide proximity to member State delegations and technical and other services that would support the work of the Chair, including assisting with preparations for all meetings, the maintenance of the Conference website and electronic newsletter, organization of activities for the International Day of Democracy and other related activities.
Not surprisingly, some countries, especially developing countries, find this situation unacceptable and look for ways to negotiate provisions in their tax treaties or, sometimes,to interpret their tax treaties when they do not contain a specific article on technical services that allow them to tax income from technical and other services.
Technical and other support services.
This could be limited to technical and other similar services;
Related to the rendering of geological, geophysical,drilling, technical and other consultancy services.
Several existing treaties have a specific provision dealing with technical and other similar services.
Article 12 could be revised to apply to fees for technical and other similar services linked to royalties.
A ban on the provision of technical training and other services related to these sectors(article 4.2);