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of <h1>Royalties and Technical Fees Tax Limited to 10% if Beneficial Owner; Exemptions for Permanent Establishments Apply.</h1> Royalties and fees for technical services arising in one Contracting State and paid to a resident of another may be taxed in both states, but the tax in the state where they arise cannot exceed 10% if the recipient is the beneficial owner. 'Royalties' include payments for the use of intellectual property, while 'fees for technical services' cover managerial, technical, or consultancy services. These provisions do not apply if the recipient has a permanent establishment in the state where the payments arise, in which case other articles apply. Payments are considered to arise where the payer is a resident or has a permanent establishment. Excess payments due to special relationships are taxed according to each state's laws.
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