Royalties and technical services fees may be taxed at source subject to beneficial owner and permanent establishment rules.

Royalties and fees for technical services arising in one Contracting State and paid to a resident of the other State may be taxed in the recipient's State of residence, while the source State may also tax such payments subject to a cap when the beneficial owner is resident elsewhere. The Article defines royalties to include payments for use of intellectual property and related information, and fees for technical services to include managerial, technical or consultancy services. Payments connected with a permanent establishment or fixed base are governed by Article 7 or Article 14, and amounts exceeding an arm's-length value due to special relationships remain taxable under domestic law.

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