Fees for technical services

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.... and according to the laws of that state, but if the beneficial owner of the fees for technical services is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the fees for technical services. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation. 3. The term "....

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.... with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 15, as the case may be, shall apply. 5. Fees for technical services shall be deemed to arise in a Contracting State when the payer is 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 ....