Taxation of royalties and technical service fees: limited withholding when recipient is beneficial owner, subject to source and PE exceptions. Royalties and fees for technical services payable between Contracting States may be taxed in the recipient's State and also in the source State; however, if the recipient is the beneficial owner, the source State's withholding is limited. The Article defines royalties and fees for technical services, excludes services under Article 15, and excepts payments effectively connected with a permanent establishment or fixed base (governed by Articles 7 or 14). Payments are deemed to arise where the payer or bearing permanent establishment is located, and special-relationship excess payments are adjusted to arm's-length amounts.