Royalties and technical services tax treatment: source-state withholding limited; connected payments governed by PE or fixed-base rules.

Payments characterised as royalties and fees for technical services may be taxed in the recipient's State while the source State may also tax them subject to a limited withholding cap when the beneficial owner is resident elsewhere. Definitions specify the scope of royalties and technical service fees; connection rules exclude payments effectively connected with a permanent establishment or fixed base, applying business profits or independent services provisions instead. Deeming rules attribute source to payer residence or the permanent establishment bearing the liability, and related-party adjustments confine treaty treatment to the arm's-length portion.

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