Fees For Technical Services

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....e laws of that State, but if the recipient is the beneficial owner of the fees for technical services and is a resident of the other Contracting State, the tax so charged shall not exceed 10 (ten) 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, other than those mentioned in Articles 12, ....

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.... 15, as the case may be, shall apply. 5. a) 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 a Contracting State a permanent establishment or a fixed base in connection with which the liability to p....