Royalties and fees for included services are subject to limited source taxation under the treaty with prescribed withholding limits. Royalties and fees for included services paid to a non resident may be taxed in the recipient's State of residence but may also be taxed at source where they arise; if the beneficial owner is resident in the other Contracting State, source taxation is capped by specified withholding limits that differ by category. The Article defines royalties and fees for included services, lists express exclusions, and provides that amounts attributable to a permanent establishment or fixed base fall under business profits or independent personal services rules. Related party excess payments may be adjusted and taxed domestically.