Royalties and fees for technical services

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....ritory in which they arise, and according to the laws of that territory, but if the beneficial owner of the royalties or fees for technical services is a resident of the other territory, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties or fees for technical services. 3.(a) The term "royalties" as used in this Article means payments of any kind received as a c....

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....if the beneficial owner of the royalties or fees for technical services, being a resident of a territory, carries on business in the other territory in which the royalties or fees for technical services arise, through a permanent establishment situated therein, or performs in that other territory independent personal services from a fixed base situated therein, and the right or property in respect....

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....chnical services shall be deemed to arise in the territory in which the permanent establishment or fixed base is situated. (b) Where under sub-paragraph (a) royalties or fees for technical services do not arise in one of the territories, and the royalties relate to the use of, or the right to use, the right or property, or the fees for technical services relate to services performed, in one of ....