Fees for technical services: source-state taxation allowed but limited when the recipient is the beneficial owner. Fees for technical services paid to a resident of the other Contracting State may be taxed in the State where they arise, but if the recipient is the beneficial owner source taxation is limited; the term covers managerial, technical or consultancy services (including personnel) and excludes services under Article 16 and professional services under Article 15. The source right is displaced where the beneficial owner has a permanent establishment or fixed base in the source State and the fees are effectively connected with that presence, and special-relationship adjustments limit application to arm's-length amounts.