Technical fees

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..... the beneficial owner of the technical fees, the tax so charged shall not exceed 1 [ 10 per cent ] of the gross amount of the technical fees. 3. The term technical 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 technical, managerial or consultancy nature. 4. The provisions of .....

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..... ontracting State or not, has in a resident of a Contracting State a permanent establishment or a fixed base in connection with which the obligation to pay the technical fees was incurred and such technical fees are borne by that permanent establishment or fixed base then such technical fees shall be deemed to arise in the Contracting State in which permanent establishment is situated. 6. Where, by .....

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