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of <h1>Technical service fees taxed up to 10% in source State; exclusions for employees and educational services.</h1> Fees for technical services arising in one Contracting State and paid to a resident of another may be taxed in the recipient's State, but also in the State where they arise, with a maximum tax rate of 10% if the recipient is the beneficial owner. 'Fees for technical services' exclude payments to employees, for educational teaching, or for personal services. These provisions do not apply if the fees are connected to a permanent establishment or fixed base in the State where they arise. Special relationships affecting fee amounts may alter tax obligations, with excess amounts taxable under each State's laws.
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