Royalties and technical service fees: source taxation allowed but limited where recipient is the beneficial owner and PE connects rights. Article 12 permits source State taxation of royalties and fees for technical services paid to residents of the other Contracting State but limits source tax where the recipient is the beneficial owner. It defines royalties and fees for technical services, excludes certain services under Article 15, and provides that where the beneficial owner's right or contract is effectively connected to a permanent establishment or fixed base in the source State, Articles governing business profits or independent personal services apply. Related party excess payments are limited to arm's length amounts for treaty purposes, with the excess taxable under domestic law.