Royalties and technical service fees may be subject to source taxation with limited withholding when beneficial owner resides abroad.

Royalties and fees for technical services paid to a resident of the other Contracting State may be taxed in the recipient's residence and also in the source State, subject to a specified withholding limit where the beneficial owner is resident in the other State. Royalties cover payments for rights to use copyrights, patents, trademarks, designs, equipment or technical information; fees for technical services cover managerial, technical or consultancy services including personnel. Exceptions apply when the beneficial owner operates through a permanent establishment or fixed base with an effective connection, in which case business or personal service provisions govern; special-relationship excesses are adjusted to arm's length amounts.

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