Royalties and technical service fees: source taxation permitted but limited where recipient is beneficial owner, with PE linkage overriding treaty rule. 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 them subject to a capped withholding limit where the recipient is the beneficial owner. Royalties encompass payments for use of copyrights, patents, trademarks, designs, processes, equipment and technical information. Fees for technical services cover non-employee managerial, technical or consultancy services. Where the beneficial owner has a permanent establishment or fixed base and the payments are effectively connected, provisions on business profits or independent personal services apply. Related-party excess payments are limited to arm's-length amounts for treaty purposes.