FEES FOR TECHNICAL SERVICES

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..... to the 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 1 .....

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..... le 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 .....

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..... h would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. - - statute, statutory provisions l .....

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