Management fees taxation may be imposed in the source state, subject to treaty limits and permanent establishment exceptions.

Management or professional fees arising in a Contracting State may be taxed in the recipient's State, while the source State may tax them subject to a treaty limit; fees mean payments (other than to employees) for managerial, technical or consultancy services. If the recipient has a permanent establishment or fixed base in the source State and the fees are effectively connected with it, provisions for business profits or independent personal services apply. Fees are deemed to arise where paid by the State, its subdivisions or a resident, or where a payer's permanent establishment incurred and bore the liability. Excess payments above arm's-length are excluded from this Article.

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