Taxation of technical service fees limited where beneficial owner is resident, allowing source-state levy subject to treaty cap. The Article permits source-state taxation of fees for technical services paid to a resident of the other Contracting Party, with a treaty limitation when the beneficial owner is resident of that other Party. It defines such fees to include managerial, technical or consultancy services and excludes independent and dependent personal services. Payments attributable to a permanent establishment or fixed base are treated as arising where that establishment or base is situated, and where special relationships inflate payments, only the arm's-length amount is governed by the Article while excess amounts remain taxable under domestic law. Treaty benefits are denied if one main purpose is treaty-shopping.