Royalties taxation limited by treaty: source withholding may apply but PE connection shifts taxation to business profits. Article 12 permits both the residence State and the source State to tax royalties and fees for included services, but limits source state taxation when the beneficial owner is resident in the other Contracting State and requires competent authorities to agree the method of applying that limitation. The Article defines royalties and fees for included services, lists express exclusions, and provides that taxation rules do not apply where the beneficial owner has a permanent establishment or fixed base in the source State and the payments are effectively connected with that presence.