Royalties and technical service fees: source taxation limited; beneficial owner cap and permanent establishment exceptions apply.

Royalties and fees for technical services payable to a resident of the other Contracting State may be taxed in the recipient State, while the State where they arise may also tax them subject to a source taxation limit when the recipient is the beneficial owner. Definitions distinguish royalties (payments for use of intellectual property, equipment, or technical information) from fees for technical services (managerial, technical or consultancy services, excluding employee remuneration). Exceptions apply where the beneficial owner has a permanent establishment or fixed base in the source State and the payments are effectively connected thereto, and special-relationship excesses are disregarded for treaty application.

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