My SaaS revenue from US customers — does Treas. Reg. 1.861-19 classify it as a service or a royalty?
I run a B2B SaaS product from my home country through a US LLC. A withholding agent at a US enterprise customer wants to apply 30% withholding treating my fee as a royalty. I think the current cloud regs classify SaaS as a service. Which is right and what does it mean for sourcing and withholding?
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