TMI BlogROYALTIES AND FEES FOR TECHNICAL SERVICESX X X X Extracts X X X X X X X X Extracts X X X X ..... axed in the Contracting State in which they arise, and according to the laws of that State, but 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 Article means payments o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and 2 shall not apply if the beneficial owner of the royalties or fees for technical services being a resident of a Contracting State, carried on business in the other Contracting State in which the royalties or fees for technic services arise, through a permanent establishment situated therein, or performs that other State independent personal services from a fixed base situated therein and the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cal services are borrow by such permanent establishment or fixed base, then such royalties or fees f technical services shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (b) Where under sub-paragraph (a) royalties or fees for technical services do not arise in one of the Contracting States, and the royalties relate to the use of or ..... X X X X Extracts X X X X X X X X Extracts X X X X
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