Limitation on source taxation applies to dividends, interest, royalties and technical service fees, reducing withholding tax under amended bilateral convention. Dividends and interest paid to a beneficial owner resident of the other Contracting State may be taxed in the source State but the tax charged is capped at 10 per cent of the gross amount. Article 12 on Royalties and Fees for Technical Services is revised to allow taxation in the source State subject to specified withholding limits, to define royalties and fees for technical services, set out exclusions, provide rules where amounts are attributable to a permanent establishment or fixed base, and to implement transitional rates and mutual agreement procedures.