Taxing right over automated digital services: source State may tax payments to nonresidents subject to a negotiated gross-based cap. Article 12B grants the source State a taxing right over income from automated digital services paid to residents of the other Contracting State, limited by a bilaterally negotiated percentage cap on gross payments; alternatively, the beneficial owner may elect (or request) taxation on qualified profits derived by applying a profitability ratio to gross revenues, with multinational enterprise group profitability usable where higher and available. The Article excludes amounts characterised as royalties or fees for technical services, preserves taxation where income is effectively connected to a permanent establishment or fixed base, and treats related-party excess payments as taxable under domestic law.