TMI BlogROYALTIES AND FEES FOR TECHNICAL SERVICESX X X X Extracts X X X X X X X X Extracts X X X X ..... lso be taxed in the Contracting State in which they arise, and according to the laws of that State, but if the beneficial owner of the royalties or fees for technical services is a resident of the other Contracting State, 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 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r personnel. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties or fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise, through a permanent establishment situated therein, or performs in that other State independen ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r fees for technical services was incurred, and such royalties or fees for technical services are borne by such permanent establishment or fixed base, then such royalties or fees for technical services shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 6. Where, by reason of a special relationship between the payer and the b ..... X X X X Extracts X X X X X X X X Extracts X X X X
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