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of <h1>Royalties and Technical Services Fees Taxed at Max 10% if Beneficial Owner Resides in Other State; Special Rules Apply.</h1> Royalties and fees for technical services arising in one Contracting State and paid to a resident of the other Contracting State may be taxed in both States, with a maximum tax rate of 10% in the State where they arise if the beneficial owner resides in the other State. 'Royalties' include payments for the use of intellectual property and equipment, while 'fees for technical services' cover managerial, technical, or consultancy services. These provisions do not apply if the beneficial owner conducts business through a permanent establishment in the State where the payments arise. Payments exceeding fair market value due to special relationships are only partially covered.
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