I really can’t anymore, resubmitting my form over and over again. And I just don’t know anymore, finally, it looks like I filled the part 10/2 well, but - RESPONSE - It looks like your tax rate is higher than it needs to be. This US IRS document will help you find the appropriate tax rate…I’m looking, I really do, I checked every convo here in the community, but I can’t figure it out. HEEEELP, please
I’m a resident of Spain …Claiming the provision and paragraph 12/2/ of the treaty identified..blah, blah, blah…5% rate…
"Article VI Article 12 (Royalties) of the Convention shall be deleted and replaced by the following:"
"1. Royalties arising in a Contracting State and beneficially owned by a resident of the other Contracting State shall be taxable only in that other State."
and
"2. 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, scientific or other work (including cinematographic films, and films and recordings for radio or television broadcasting), any patent, trademark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience."
So, in your case, the correct Article and Paragraph is 12(1) and the Royalty Rate is 0%.
De nada. Always glad to help, went through the same struggles. If there are no issues with the other information, especially the infamous “Additional Conditions”, things should work. Note that if you don’t get an answer this is usually good news.
I think I read your article today about - how to fill those things, and it helped. Just to get past this percentage and paragraphs and hopefully that’s it.