TMI BlogROYALTIES AND FEES FOR TECHNICAL OR PROFESSIONAL SERVICESX X X X Extracts X X X X X X X X Extracts X X X X ..... r fees for technical or professional services may also 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 or professional 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 or pr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... consultancy services, including the provision of services of technical or other personnel; or (ii) professional services including independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of physicians, lawyers, engineers, architects, surgeons, dentists and accountants. 4. The provisions of paragraph 1 and 2 shall not apply ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hat State. Where, however, the person paying the royalties or fees for technical or professional services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the liability to pay the royalties or fees for technical or professional services was incurred, and such royalties or fees for technical or professional servic ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... son, the amount of the royalties or fees for technical or professional services, having regard to the use, right or information for which they are paid, exceeds the amount which 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 paym ..... X X X X Extracts X X X X X X X X Extracts X X X X
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