Royalties and technical service fees: source taxation allowed but limited when paid to a resident beneficial owner; PE exceptions apply. Cross-border royalties and fees for technical services may be taxed in the source State, but where the beneficial owner is resident in the other Contracting State the source tax is limited to a reduced rate. 'Royalties' covers payments for use of intellectual property, equipment or proprietary information; 'fees for technical services' covers managerial, technical or consultancy services including provision of personnel. If the beneficial owner carries on business via a permanent establishment or fixed base and the payments are effectively connected, rules for business profits or independent personal services apply. Deemed-source rules follow payer residence or the permanent establishment connection, and special-relationship adjustments limit treaty relief to arm's-length amounts.