Fees for Technical Services

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....and according to the laws of that Party, but if the beneficial owner of the fees for technical services is a resident of the other Contracting Party the tax so charged shall not exceed 10 per cent of the gross amount of the fees for technical services. 3. The term "fees for technical services" as used in this Article means payments of any kind as consideration for managerial, technical or consu....

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....t 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 Party when the payer is a resident of that Party. Where, however, the person paying the fees for technical services, whether he is a resident of a Contracting Party or not, has in a Contracting Party a pe....