Royalties and Fees for Technical Services: source-state may tax with capped withholding rates, subject to beneficial owner and PE exceptions. Article 13 permits residence-state taxation but allows the source State to tax royalties and fees for technical services paid to residents of the other Contracting State subject to specified withholding caps and categorical distinctions. It defines 'royalties' to include payments for use of intellectual property and equipment, and defines 'fees for technical services' to encompass ancillary services, know how transfers, and technical plans, while listing explicit exclusions. Nexus and anti abuse rules displace source state treatment where amounts are effectively connected with a permanent establishment or fixed base, apply arm's length adjustments for related party excess payments, and bar treaty benefits when obtaining them was a principal purpose of a transaction.