Taxation of technical service fees: source-state tax limited where beneficial owner is resident, with permanent establishment exceptions.

Fees for technical services are taxable in both the recipient's residence State and the State where they arise, but source-state taxation is limited when the beneficial owner is resident of the other Contracting State. The Article defines such fees to include managerial, technical or consultancy services and excludes certain other service categories. The limitation does not apply when fees are effectively connected with a permanent establishment or fixed base, in which case rules on business profits or independent personal services govern. Special-relationship payments exceeding arm's-length amounts are adjusted and excess remains taxable under domestic law.

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