Royalty and technical services taxation: limited withholding by source State with resident beneficial-owner protection and PE exceptions. Royalties and fees for technical services payable to a resident of the other Contracting State may be taxed in the recipient's State, while the source State may also tax such payments subject to a capped rate where the beneficial owner is resident in the other State. Definitions: Royalties include payments for use of copyrights, patents, trademarks, designs, equipment, and technical information; Fees for technical services cover managerial, technical or consultancy services and provision of personnel. Payments connected with a permanent establishment or fixed base are taxed under business profits or independent personal services rules, and related-party excesses are limited to arm's-length amounts.