Fees for technical services receive source-State taxation subject to beneficial ownership, treaty limitation, and permanent-establishment connection rules.

Fees for technical services may be taxed in both the recipient's State of residence and the State in which they arise, with source-State tax capped at 10 per cent of the gross amount where the beneficial owner is resident in the other Contracting State. The cap does not apply where the relevant right or property is effectively connected with a permanent establishment or fixed base in the source State. Amounts exceeding an independent-party price because of a special relationship remain taxable under domestic law.

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