Technical fees may be taxed in the source state, with limited source taxation for beneficial owners and PE exceptions.

Payments defined as technical fees for technical, managerial or consultancy services may be taxed in the payer's State of source, but if the recipient is the beneficial owner such source taxation shall not exceed 10 per cent of the gross amount. Fees connected to a recipient's permanent establishment or independent personal services in the source State are excluded from this source withholding and are governed by the provisions on business profits or independent personal services. Inflated payments arising from special relationships are confined to the arm's-length amount for treaty application.

---

---

---