Taxation of royalties and technical service fees: source state may tax with limited withholding when beneficial owner is non-resident. Royalties and fees for technical services may be taxed in the recipient's State of residence and also in the source State, but if the beneficial owner is resident of the other Contracting State the source State's tax is limited to a 10 per cent withholding. Definitions specify what constitutes royalties and fees for technical services. The withholding limit does not apply when the beneficial owner has a permanent establishment or fixed base in the source State and the right or property is effectively connected. A special-relationship rule restricts taxation to arm's-length amounts.