Management and professional fees may be subject to source taxation with a limited rate; PE connection shifts treatment to business profits.

Article 15 provides that management or professional fees may be taxed in the recipient's State, while the source State may also tax them subject to a limited source tax. The Article defines such fees as payments (other than to employees) for managerial, technical, professional or consultancy services. If the recipient has a permanent establishment in the source State and the fees are effectively connected with it, the limited source tax does not apply and business profits rules govern. Deeming rules determine when fees arise and special-relationship arm's-length adjustments limit treaty application to the appropriate amount.

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