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of <h1>Tax Limit on Technical Service Fees: Max 10% if Beneficial Owner Resides in Other Contracting Party. Exceptions Apply.</h1> Fees for technical services arising in one Contracting Party and paid to a resident of the other may be taxed in both parties, but the tax in the originating party shall not exceed 10% if the beneficial owner is a resident of the other party. 'Fees for technical services' cover payments for managerial, technical, or consultancy services but exclude independent and dependent personal services. Exceptions apply if the beneficial owner operates through a permanent establishment or fixed base in the originating party. Payments exceeding fair market value due to special relationships are taxable beyond the agreed amount, and benefits are denied if services aim to exploit the Article.
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