Royalties and fees for included services: limited source-state taxation with prescribed maximum withholding rates and permanent establishment exceptions.

Article 12 permits taxation of royalties and fees for included services in the recipient's State, while allowing the source State to tax them subject to specified maximum withholding rates for different categories and transitional periods. The Article defines royalties and fees for included services, excludes specified service types from the fees definition, provides deeming rules on source and permanent establishment linkage, and limits source taxation where payments exceed arm's length amounts between related parties.

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