Management fees

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....ng to the law of that State, but the tax so charged shall not exceed twenty per cent of the gross amount of the management or professional fees. 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 any services of a managerial, technical or consultancy natur....

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....tical sub-division, a local authority or a resident of that State. Where, however the person paying the management or professional fees, whether he is a resident 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....