Article 14 - Technical fees

Technical fees: treaty permits source-state taxation with limited withholding where beneficial owner status and PE exceptions apply.

Article 14 permits source-State taxation of technical fees arising in a Contracting State but limits the source-State withholding where the recipient is the beneficial owner to the substituted notified rate; it defines technical fees as payments for technical, managerial or consultancy services (other than to employees). The Article excludes this regime when fees are effectively connected to a permanent establishment or fixed base, directs application of Article 7 or 16 in that case, deems source based on the payer or PE/fixed base bearing the liability, and requires arm's-length adjustment where special relationships inflate payment amounts.