Royalties and technical service fees may be taxed at source, subject to a beneficial owner cap and PE exceptions. Royalties and fees for technical services arising in a Contracting State may be taxed in that State, though source taxation is limited when the recipient is the beneficial owner. 'Royalties' covers payments for use of intellectual property, equipment, or technical information; 'fees for technical services' covers managerial, technical or consultative services including provision of technical personnel. The Article excludes source taxation where the beneficial owner has a permanent establishment or fixed base in the source State and the payments are effectively connected; it also limits application to arm's-length amounts where special relationships affect payment levels and contains an anti-abuse main-purpose provision.