Royalties taxation: source state may withhold tax but a limited withholding cap applies when recipient is beneficial owner.

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, while the source State may also tax such payments subject to a limited withholding cap if the recipient is the beneficial owner; definitions of "royalties" and "fees for technical services" are provided, and exceptions apply where amounts are effectively connected with a permanent establishment or fixed base, with deemed source rules and an arm's-length adjustment for special relationships.

---

---

---