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          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.

          Provisions expressly mentioned in the judgment/order text.

          <h1>Royalties and technical service fees: source-state withholding limited where the beneficial owner is a resident of the other State.</h1> Article 12 permits residence-state taxation and allows source-state taxation of royalties and fees for technical services, subject to a reduced withholding when the beneficial owner is resident in the other Contracting State. It defines royalties and fees for technical services, exempts the reduced source treatment when amounts are effectively connected with a permanent establishment or fixed base (where Articles on business profits or independent personal services apply), sets deeming rules for source determination, and limits treaty relief where related parties inflate payments above arm's length amounts.

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