Royalties and technical service fees taxable in source state but limited when received by the beneficial owner.

Article 12 provides that royalties and fees for technical services arising in one Contracting State and paid to a resident of the other may be taxed in both States, with source taxation of amounts paid to the beneficial owner subject to a limited withholding cap. It defines "royalties" and "fees for technical services," excludes payments covered by Articles 14 and 15 from technical services, treats amounts connected with a permanent establishment or fixed base as arising in the State where that presence is situated, and limits application to arm's length amounts where special relationships inflate payments.

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