Royalties and technical service fees: source-state may tax with capped withholding, but permanent establishment nexus overrides. Royalties and fees for technical services arising in a Contracting State and paid to a resident of the other State may be taxed in the recipient's residence; the source State may also tax them but, where the beneficial owner is resident in the other State, source taxation is subject to a capped withholding rate. Royalties cover payments for use of intellectual property and related industrial/commercial/scientific information; fees for technical services cover managerial, technical or consultancy services including technical personnel. The withholding regime does not apply where the beneficial owner has a permanent establishment or fixed base in the source State and the payments are effectively connected there; deemed-source rules and related party arm's length adjustments also apply.