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of <h1>Fees for Technical Services Taxed in Both States, Capped at 10% if Beneficial Owner Resides Elsewhere.</h1> Fees for technical services arising in one Contracting State and derived by a resident of the other Contracting State may be taxed in the resident's State. However, they can also be taxed in the State where they arise, with a tax rate not exceeding 10% if the beneficial owner resides in the other State. 'Fees for technical services' include payments for managerial, technical, or consultancy services but exclude certain services under Articles 15 and 16. Exceptions apply if the beneficial owner has a permanent establishment or fixed base in the State where the fees arise, in which case Articles 7 or 15 apply. Fees are deemed to arise where the payer resides unless connected to a permanent establishment. Payments exceeding fair amounts due to special relationships are taxable under each State's law.
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