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of <h1>Technical Service Fees: Cross-Border Taxation Rules Define Payment Structures and Bilateral Tax Rate Limits Under Section 9</h1> Statutory provisions outline taxation rules for technical service fees between contracting states. The text defines technical services as managerial, technical, or consultancy payments, with specific exclusions for employee, educational, and personal services. Fees can be taxed in the state of origin and recipient's state, with a maximum tax rate to be negotiated bilaterally. Special provisions address taxation when services are connected to permanent establishments or involve related parties, ensuring appropriate tax treatment and preventing potential abuse.
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