Taxation of royalties and technical service fees: source taxation permitted, with treaty limits and PE connectivity determining relief. Royalties and fees for technical services arising in one Contracting State and paid to a resident of the other may be taxed in the recipient's State but may also be taxed in the source State; fees for technical services under post entry contracts are subject to a capped source rate, with any subsequently agreed lower rate applying. Royalties and fees for technical services are defined respectively to cover payments for use or rights in intellectual property and payments (other than to employees) for managerial, technical or consultancy services. The treaty excludes source taxation where the beneficial owner's activities are effectively connected with a permanent establishment or fixed base, and limits treaty application to arm's length amounts where related party arrangements inflate payments.