Technical fees

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....ting State; but if the recipient is the beneficial owner of the technical fees, the tax so charged shall not exceed ^1[ten per cent (10%)] of the gross amount of the technical fees. 3. The term technical 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 any services of a technical, managerial ....

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....tate. However, where the person paying the technical fees, whether he is a resident of that Contracting State or not, has in that Contracting State a permanent establishment or a fixed base in connection with which the liability to pay the technical fees was incurred, and such technical fees are borne by such permanent establishment or fixed base then the technical fees shall be deemed to arise in....