Fees for technical services

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.... the laws of that State; but if the recipient is the beneficial owner of the fees for the technical services, the tax so charged shall not exceed 10 per cent of the gross amount of such fees. 3. The term "fees for technical services" 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 any ser....

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....y body thereof, or a resident of that State. Where, however, the person paying the fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the fees for technical services was incurred, and such fees for technical services are borne by that permanent establishment, then s....