Royalties and fees for technical services: source-state taxation permitted with a beneficial-owner tax limitation and PE exceptions.

Article 12 permits taxing of royalties and fees for technical services in the recipient's residence State and also in the source State, subject to a tax ceiling where the recipient is the beneficial owner. The Article defines royalties and fees for technical services, excludes payments effectively connected with a permanent establishment or fixed base (where other Articles apply), attributes source to the payer or the payer's permanent establishment when liable, and requires arm's-length adjustment where special relationships inflate payments.

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