Fees for technical services: source State may tax payments to nonresident beneficial owners, subject to treaty limits and connection exceptions. Fees for technical services may be taxed in the State where they arise, subject to a treaty limitation when the beneficial owner is resident in the other Contracting State. 'Fees for technical services' covers payments for managerial, technical or consultancy services with specified exclusions. Fees are deemed to arise where the payer is resident or where a payer's permanent establishment or fixed base incurred the obligation, except where such fees are borne by an establishment or fixed base outside that State. If the beneficial owner has a permanent establishment or fixed base in the source State and fees are effectively connected, provisions for business profits or independent personal services apply. Related party pricing is limited to arm's-length amounts for treaty application.