Management and professional fees

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....taxed in the Contracting State in which they arise, and according to the law of that State, but the tax so charged shall not exceed 1/2 per cent. of the gross amount of the management or professional fee 3. The term "management or professional fees" as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for....

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....nt of that State or not, has in a Contracting State a permanent establishment in connection with which the liability to pay the management, or professional fees was incurred and such management or professional fees are borne by such permanent establishment, then such management or professional fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. ....