Taxation of royalties and technical service fees allows source taxation with a capped rate and PE-based exceptions.

Royalties and fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in the recipient's State, while the State of source may also tax such payments subject to a prescribed maximum rate where the beneficial owner is a resident of the other State; payments are deemed to arise where the payer is resident or where incurred by a permanent establishment or fixed base, and amounts between related parties are limited to an arm's-length figure with excess taxed under domestic law.

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