Common use of FEES FOR TECHNICAL SERVICES Clause in Contracts

FEES FOR TECHNICAL SERVICES. (1) Fees for technical services arising in a Contracting State and paid to an enterprise of the other Contracting State may be taxed in that other State. (2) However, such fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner thereof, the tax so charged shall not exceed 10 per cent of the gross amount of the fees. (3) The term "fees for technical services" as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerial, technical or consultancy nature. (4) The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the fees for technical services arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the contract in respect of which the fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 15, as the case may be, shall apply. (5) Fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or 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 obligation to make the payments was incurred, and the payments are borne by such permanent establishment or fixed base, then such fees for technical services shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the fees for technical services, exceeds the amount which would have been paid 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 Convention.

FEES FOR TECHNICAL SERVICES. (1) . Fees for technical services arising in a Contracting State and paid to an enterprise of the other Contracting State may be taxed in that other State. (2) . However, such fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner thereof, the tax so charged shall not exceed 10 per cent 10% of the gross amount of the fees. (3) . The term "fees for technical services" as used in this Article means payments any consideration (including any lump sum consideration) for the rendering of any kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerial, technical or consultancy natureservices (including the provision by the enterprise of the services of technical or other personnel), but does not include consideration for any construction, assembly or like project undertaken by the recipient or consideration which would be income falling under Article 15 of the Agreement. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the fees for technical services arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, therein and the contract in respect of which the fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 15, as the case may be, shall apply. (5) . Fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local or statutory authority or 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 obligation to make the payments was incurred, and the payments are borne by such permanent establishment or fixed baseestablishment, then such fees for technical services shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) Where, . Where by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the fees for technical services, services exceeds the amount which would have been paid 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 ConventionAgreement.

FEES FOR TECHNICAL SERVICES. (1) . Fees for technical services arising in a Contracting State and paid to an enterprise a resident of the other Contracting State may be taxed in that other State. (2) . However, such fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is where the beneficial owner thereofof the 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 fees. (3) The term "fees for technical services" . 3. The term “fees for technical services” as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerialtechnical, technical managerial or consultancy nature. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the fees for technical services arise, arise through a permanent establishment or a fixed base situated therein, or performs in that other State independent personal services from a fixed base situated thereinservices, and the contract in respect of which the fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case a case, the provisions of Article 7 or Article 15, as the case may be, shall apply. (5) . Fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or 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 obligation to make pay the payments fees for technical services was incurred, and the payments such fees for technical services are borne by such permanent establishment or a fixed base, then such fees for technical services shall be deemed to arise in the Contracting State in which the permanent establishment or a fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the fees for technical servicesservices paid exceeds, exceeds for whatever reason, the amount which would have been paid 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 ConventionAgreement.

FEES FOR TECHNICAL SERVICES. (1) . Fees for technical services arising in a Contracting State and paid to an enterprise which are derived by a resident of the other Contracting State may be taxed in that other State. (2) . However, such fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner thereof, of the fees for technical services is a resident of the other Contracting State the tax so charged shall not exceed 10 per cent percent of the gross amount of the feesfees for technical services. (3) . The term "fees for technical services" as used in this Article means payments payment of any kind to any person, other than payments to an employee of the person making the payments, in consideration for the rendering of any services of a managerial, technical or consultancy natureservices including the provision of services by technical or other personnel but does not include payments for services mentioned in Article 15 and Article 16 of this Agreement. (4) . The provisions of paragraphs paragraph 1 and 2 of this Article shall not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the fees for technical services arise, arise through a permanent establishment situated therein, or performs in that other State independent personal personnel services from a fixed base situated therein, and the contract in respect of which the fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case case, the provisions of Article 7 or Article 15, as the case may be, shall apply. (5) . Fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or 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 obligation to make pay the payments fees for technical services was incurred, and the payments such fees for technical services are borne by such permanent establishment or fixed base, then such 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 beneficial owner or between both of them and some other person, the amount of the fees for technical servicesservices paid exceeds, exceeds for whatever reason, the amount which would have been paid agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall only apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws law of each Contracting State, due regard being had to the other provisions of this ConventionAgreement.

FEES FOR TECHNICAL SERVICES. (1) . Fees for technical services arising in a Contracting State and paid to an enterprise a resident of the other Contracting State may be taxed in that other State. (2) . However, such fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is where the beneficial owner thereof, of the 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 feesfees for technical services. (3) . The term "fees for technical services" as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerialtechnical, technical managerial or consultancy nature. (4) . The provisions of paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the fees for technical services arise, arise through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the contract in respect of which the fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such a case the provisions of Article 7 or Article 15, as the case may be, shall apply. (5) . Fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or 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 obligation to make pay the payments fees for technical services was incurred, and the payments such fees for technical services are borne by such permanent establishment or fixed base, then such fees for technical services shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is in situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the fees for technical servicesservices paid exceeds, exceeds for whatever reason, the amount which would have been paid 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-last- mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws law of each Contracting State, due regard being had to the other provisions of this ConventionAgreement.

FEES FOR TECHNICAL SERVICES. (1) . Fees for technical services arising in a Contracting State and paid to an enterprise a resident of the other Contracting State may be taxed in that other State. (2) . However, such fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is where the beneficial owner thereof, of the fees for technical services is a resident of the other Contracting State the tax so charged shall not exceed 10 per cent percent of the gross amount of the feesfees for technical services. (3) . The term "fees for technical services" as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerialtechnical, technical managerial or consultancy nature. (4) . The provisions of paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the fees for technical services arise, arise through a permanent establishment situated therein, or performs in that other State independent personal personnel services from a fixed base situated therein, and the contract in respect of which the fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such a case the provisions of Article 7 or Article 1514, as the case may be, shall apply. (5) . Fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory thereof, or 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 obligation to make pay the payments fees for technical services was incurred, and the payments such fees for technical services are borne by such permanent establishment or fixed base, then such 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 beneficial owner or between both of them and some other person, the amount of the fees for technical servicesservices paid exceeds, exceeds for whatever reason, the amount which would have been paid 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 law of each Contracting State, due regard being had to the other provisions of this ConventionAgreement.

FEES FOR TECHNICAL SERVICES. (1) . Fees for technical services arising in derived from one of the Contracting States by a Contracting State and paid to an enterprise resident of the other Contracting State who is the beneficial owner thereof and is subject to tax in that other State in respect thereof may be taxed in that other State. (2) However, such fees for technical services may also be taxed in the first-mentioned Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner thereof, the tax so charged shall at a rate not exceed 10 exceeding 5 per cent of the gross amount of the such fees. (3) 2. The term "fees for technical services" as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerialtechnical, technical managerial or consultancy nature. (4) 3. The provisions of paragraphs paragraph 1 and 2 shall not apply if the beneficial owner of the fees for technical services, services being a resident of a Contracting State, carries on business in the other Contracting State in which the fees for technical services arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the contract in respect of which the fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case a case, the provisions of Article 7 or Article 15, as the case may be, shall apply. (5) 4. Fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a resident of that State. Where, however, the person paying the fees for technical services, whether he that person 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 obligation to make pay the payments fees for technical services was incurred, and the payments such fees are borne by such permanent establishment or fixed base, then such fees for technical services shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the fees for technical servicesservices paid exceeds, exceeds for whatever reason, the amount which would have been paid 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 ConventionAgreement.

FEES FOR TECHNICAL SERVICES. (1) . Fees for technical services arising in a Contracting State and paid to an enterprise a resident of the other Contracting State may be taxed in that other Contracting State. (2) . However, such fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that Contracting State, but if the recipient is the beneficial owner thereofof the 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 fees. (3) The term "fees for technical services" . 3. The term “fees for technical services” as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the payments, in received as a consideration for the rendering of any services of a managerial, technical or consultancy natureservices including the services of technical or other personnel, but does not include payments of any kind received as: (a) a consideration for any construction, assembly, installation or any other similar project, or supervisory activities in connection therewith; (b) a consideration for the rendering of independent personal services referred to in Article 15; or (c) a consideration of an employment referred to in Article 16. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the fees for technical services arise, arise through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, therein and the contract contracts in respect of which the fees for technical services are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 15, as the case may be, shall apply. (5) . Fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a resident of that Contracting 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 obligation liability to make pay the payments fees for technical services was incurred, and the payments such fees for technical services are borne by such permanent establishment or fixed base, then such 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 beneficial owner or between both of them and some other person, the amount of the fees for technical services, having regard to the contracts for which they are paid, exceeds the amount which would have been paid 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 Convention.

FEES FOR TECHNICAL SERVICES. (1) . Fees for technical services arising in a Contracting State and paid to an enterprise a resident of the other Contracting State may shall be taxed in that other State. (2) . However, such fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is where the beneficial owner thereof, of the 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 feesfees for technical services. (3) . The term "fees for technical services" as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerialtechnical, technical managerial or consultancy nature. (4) . The provisions of paragraphs paragraph 1 and 2 of this Article shall not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the fees for technical services arise, arise through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated thereinservices, and the contract in respect of which the fees for technical services are paid is effectively connected with such permanent establishment or fixed basesuch services. In such case a case, the provisions of Article 7 or Article 15, as the case may be, shall apply. (5) . Fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or 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 obligation to make pay the payments fees for technical services was incurred, and the payments such fees for technical services are borne by such permanent establishment or fixed baseestablishment, then such 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 beneficial owner or between both of them and some other person, the amount of the fees for technical servicesservices paid exceeds, exceeds for whatever person, the amount which would have been paid 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-last- mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws law of each Contracting State, due regard being had to the other provisions of this ConventionAgreement.

FEES FOR TECHNICAL SERVICES. (1) . Fees for technical services arising in a Contracting State and paid to an enterprise a resident of the other Contracting State may be taxed in that other State. (2) . However, such fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is where the beneficial owner thereof, of the fees for technical services is a resident of the other Contracting State the tax so charged shall not exceed 10 per cent percent of the gross amount of the feesfees for technical services. (3) . The term "fees for technical services" as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerialtechnical, technical managerial or consultancy nature. (4) . The provisions of paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the fees for technical services arise, arise through a permanent establishment situated therein, or performs in that other State independent personal personnel services from a fixed base situated therein, and the contract in respect of which the fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such a case the provisions of Article 7 or Article 15, as the case may be, shall apply. (5) . Fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or 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 obligation to make pay the payments fees for technical services was incurred, and the payments such fees for technical services are borne by such permanent establishment or fixed base, then such 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 beneficial owner or between both of them and some other person, the amount of the fees for technical servicesservices paid exceeds, exceeds for whatever reason, the amount which would have been paid 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 law of each Contracting State, due regard being had to the other provisions of this ConventionAgreement.

FEES FOR TECHNICAL SERVICES. (1) . Fees for technical services arising in a Contracting State and paid to an enterprise a resident of the other Contracting State may be taxed in that other State. (2) . However, such fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is where the beneficial owner thereof, of the fees for technical services is a resident of the other Contracting State the tax so charged shall not exceed 10 8 per cent of the gross amount of the feesfees for technical services. (3) . The term "fees for technical services" as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerialtechnical, technical managerial or consultancy nature. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the fees for technical services arise, arise through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the contract in respect of which the fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such a case the provisions of Article 7 or Article 15, as the case may be, shall apply. (5) . Fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or 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 obligation to make pay the payments fees for technical services was incurred, and the payments such fees for technical services are borne by such permanent establishment or fixed base, then such 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 beneficial owner or between both of them and some other person, the amount of the fees for technical servicesservices paid exceeds, exceeds for whatever reason, the amount which would have been paid 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-last- mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws law of each Contracting State, due regard being had to the other provisions of this ConventionAgreement.

FEES FOR TECHNICAL SERVICES. (1) . Fees for technical services arising in a Contracting State and paid to an enterprise a resident of the other Contracting State may be taxed in that other State. (2) . However, such fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is where the beneficial owner thereof, of the fees for technical services is a resident of the other Contracting State the tax so charged shall not exceed 10 8 per cent of the gross amount of the feesfees for technical services. (3) . The term "fees for technical services" as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerialtechnical, technical managerial or consultancy nature. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the fees for technical services arise, arise through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the contract in respect of which the fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such a case the provisions of Article 7 or Article 15, as the case may be, shall apply. (5) . Fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or 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 obligation liability to make pay the payments fees for technical services was incurred, and the payments such fees for technical services are borne by such permanent establishment or fixed base, then such 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 beneficial owner or between both of them and some other person, the amount of the fees for technical services, having regard to the services for which they are paid, exceeds the amount which would have been paid 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 [laws] of each Contracting State, due regard being had to the other provisions of this ConventionAgreement.

FEES FOR TECHNICAL SERVICES. (1) . Fees for technical services arising in a Contracting State and paid to an enterprise a resident of the other Contracting State may be taxed in that other State. (2) . However, such fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is where the beneficial owner thereof, of the fees for technical services is a resident of the other Contracting State the tax so charged shall not exceed 10 per cent 8 percent of the gross amount of the feesfees for technical services. (3) . The term "fees for technical services" as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerialtechnical, technical managerial or consultancy nature. (4) . The provisions of paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the fees for technical services arise, arise through a permanent establishment situated therein, or performs in that other State independent personal personnel services from a fixed base situated therein, and the contract in respect of which the fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such a case the provisions of Article 7 or Article 15, as the case may be, shall apply. (5) . Fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or 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 obligation to make pay the payments fees for technical services was incurred, and the payments such fees for technical services are borne by such permanent establishment or fixed base, then such 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 beneficial owner or between both of them and some other person, the amount of the fees for technical servicesservices paid exceeds, exceeds for whatever reason, the amount which would have been paid 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-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 ConventionAgreement.

FEES FOR TECHNICAL SERVICES. (1) . Fees for technical services arising in a Contracting State and paid to an enterprise a resident of the other Contracting State may be taxed in that other State. (2) . However, such fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner thereof, of the fees for technical services is a resident of the other Contracting State the tax so charged shall not exceed 10 5 per cent of the gross amount of the feesfees for technical services. (3) . The term "fees for technical services" as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerialtechnical, technical managerial or consultancy nature. (4) . The provisions of paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the fees for technical services arise, arise through a permanent establishment situated therein, or performs in that other State professional services or other activities of an independent personal services character from a fixed base situated thereindeemed permanent establishment, and the contract in respect of which the fees for technical services are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such a case the provisions of Article 7 or Article 15, as the case may be, shall apply. (5) . Fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or 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 obligation to make pay the payments fees for technical services was incurred, and the payments such fees for technical services are borne by such permanent establishment or fixed baseestablishment, then such 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 beneficial owner or between both of them and some other person, the amount of the fees for technical servicesservices paid exceeds, exceeds for whatever reason, the amount which would have been paid 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 ConventionAgreement.

FEES FOR TECHNICAL SERVICES. (1) . Fees for technical services arising in a Contracting State and paid to an enterprise which are derived by a resident of the other Contracting State may be taxed in that other State. (2) . However, such fees for technical services may also be taxed in the Contracting State in which they arise arise, and according to the laws of that State, ; but if the recipient is the beneficial owner thereofof the fees for the technical services, the tax so charged shall not exceed 10 per cent cent. of the gross amount of the such fees. (3) . The term "fees for technical services" as used in this Article article means payments payment of any kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerialtechnical, technical managerial or consultancy nature. (4) . The provisions of paragraphs 1 and 2 4 shall not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting State, State carries on business in the other Contracting State in which the fees for technical services arise, arise through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated thereinservices, and the contract in respect of which the fees for the technical services are paid is effectively connected with such permanent establishment or fixed basesuch services. In such case case, the provisions of Article 7 or Article 15, as the case may be, shall apply. (5) . Fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivisionsub-division, a local authority or a statutory body thereof, or 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 obligation to make pay the payments fees for technical services was incurred, and the payments such fees for technical services are borne by such that permanent establishment or fixed baseestablishment, then such 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 beneficial owner recipient or between both of them and some other person, the amount of the fees paid for technical services, exceeds for whatever reason, the amount which would have been paid agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article 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 law of each Contracting State, State due regard being had to the other provisions of this Convention.

FEES FOR TECHNICAL SERVICES. (1) Fees for technical services arising in a Contracting State and paid to an enterprise a resident of the other Contracting State may be taxed in that other State. (2) However, such fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is where the beneficial owner thereofof the fees for technical services is a resident of the other Contracting State, the tax so charged shall not exceed 10 7.5 per cent of the gross amount of the feesfees for technical services. (3) The term "“fees for technical services" ” as used in this Article means payments of any an}/ kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerialtechnical, technical managerial or consultancy nature. (4) The provisions of paragraphs 1 (1) and 2 (2) shall not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting State, carries on business in iin the other Contracting State in which the fees for technical services arise, arise through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the contract in respect of which the fees for technical services are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case case, the provisions of Article 7 or Article 15, as the case may be, shall apply. (5) Fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or 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 obligation to make pay the payments fees for technical services was incurred, and the payments such fees for technical services are borne by such permanent establishment or fixed baseestablishment, then such 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, Where by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the fees for technical servicesservices paid exceeds, exceeds for whatever reason, the amount which would have been paid agreed upon by the payer and the beneficial owner in the absence of such a 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 ConventionAgreement.

FEES FOR TECHNICAL SERVICES. (1) . Fees for technical services arising in a Contracting State and paid to an enterprise a resident of the other Contracting State may be taxed in that other State. (2) . However, such fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is where the beneficial owner thereof, of the fees for technical services is a resident of the other Contracting State the tax so charged shall not exceed 10 per cent 8 percent of the gross amount of the feesfees for technical services. (3) . The term "fees for technical services" as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerialtechnical, technical managerial or consultancy nature. (4) . The provisions of paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the fees for technical services arise, arise through a permanent establishment situated therein, or performs in that other State independent personal personnel services from a fixed base situated therein, and the contract in respect of which the fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such a case the provisions of Article 7 or Article 15, as the case may be, shall apply. (5) . Fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or 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 obligation to make pay the payments fees for technical services was incurred, and the payments such fees for technical services are borne by such permanent establishment or fixed base, then such 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 beneficial owner or between both of them and some other person, the amount of the fees for technical servicesservices paid exceeds, exceeds for whatever reason, the amount which would have been paid 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-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 ConventionAgreement.

FEES FOR TECHNICAL SERVICES. (1) . Fees for technical services arising in a Contracting State and paid to an enterprise a resident of the other Contracting State may be taxed in that other State. (2) . However, such fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is where the beneficial owner thereof, of the fees for technical services is a resident of the other Contracting State the tax so charged shall not exceed 10 per cent 8 percent of the gross amount of the fees. (3) The term "fees for technical services" . 3. The term “fees for technical services” as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerialtechnical, technical managerial or consultancy nature. (4) . The provisions of paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the fees for technical services arise, arise through a permanent establishment situated therein, or performs in that other State independent personal personnel services from a fixed base situated therein, and the contract in respect of which the fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such a case the provisions of Article 7 or Article 15, as the case may be, shall apply. (5) . Fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or 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 obligation to make pay the payments fees for technical services was incurred, and the payments such fees for technical services are borne by such permanent establishment or fixed base, then such 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 beneficial owner or between both of them and some other person, the amount of the fees for technical servicesservices paid exceeds, exceeds for whatever reason, the amount which would have been paid 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 ConventionAgreement.

FEES FOR TECHNICAL SERVICES. (1) . Fees for technical services arising in a Contracting State Party and paid to an enterprise a resident of the other Contracting State Party may be taxed in that other StateParty. (2) . However, such fees for technical services may also be taxed in the Contracting State Party in which they arise and according to the laws of that StateParty, but if the recipient is the beneficial owner thereofof the fees for technical services is a resident of the other Contracting Party, the tax so charged shall not exceed 10 five (5) per cent of the gross amount of the fees. (3) The term "fees for technical services" . 3. The term “fees for technical services” as used in this Article means payments of any kind to any person, other than payments to an employee of the person pers on making the payments, in consideration for any services of a managerialtechnical, technical managerial or consultancy nature. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting StateParty, carries on business in the other Contracting State Party in which the fees for technical services arise, arise through a permanent establishment situated therein, or performs in that other State Party independent personal services from a fixed base situated therein, and the contract in respect of which the fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 15, as the case may be, shall apply. (5) . Fees for technical services shall be deemed to arise in a Contracting State Party when the payer is that State itself, a political subdivision, a local authority or a resident of that StateParty. Where, however, the person paying the fees for technical services, whether he is a resident of a Contracting State Party or not, has in a Contracting State Party a permanent establishment or a fixed base in connection with which the obligation to make pay the payments fees for technical services was incurred, and the payments such fees for technical services are borne by such permanent establishment or fixed base, then such fees for technical services shall be deemed to arise in the State Party in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the fees for technical servicesservices paid exceeds, exceeds for whatever reasons, the amount which would have been paid 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 lastmentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting StateParty, due regard being had to the other provisions of this ConventionAgreement.

FEES FOR TECHNICAL SERVICES. (1) . Fees for technical services arising in a Contracting State and paid to an enterprise which are derived by a resident of the other Contracting State may be taxed in that other State. (2) . However, such fees for technical services may also be taxed in the Contracting State in which they arise arise, and according to the laws of that State, but if the recipient is the beneficial owner thereofof the fees for technical services, the tax so charged shall not exceed 10 per cent of the gross amount of the feesfees for technical services. (3) . The term "fees for technical services" as used in this Article means payments payment of any kind to any person, other than payments to an employee of the person making the payments, in consideration for the rendering of any services of a managerial, technical or consultancy natureservices, including the provision by the enterprise of the services of technical or other personnel, but does not include payments for services to which Article 15 of this Agreement applies. (4) . The provisions of paragraphs paragraph 1 and 2 of this Article shall not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the fees for technical services arise, arise through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the contract in respect of which the fees for technical services are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case case, the provisions of Article 7 or Article 15, as the case may be, shall apply. (5) . Fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or 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 obligation to make pay the payments fees for technical services was incurred, and the payments such fees for technical services are borne by such permanent establishment or fixed base, then such 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 beneficial owner or between both of them and some other person, the amount of the fees for technical servicesservices paid exceeds, exceeds for whatever reason, the amount which would have been paid agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall only apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws law of each Contracting State, due regard being had to the other provisions of this ConventionAgreement.

FEES FOR TECHNICAL SERVICES. (1) . Fees for technical services arising in a Contracting State and paid to an enterprise a resident of the other Contracting State may be taxed in that other State. (2) . However, such notwithstanding the provisions of Article 7 and subject to the provisions of Articles 8, 16 and 17, fees for technical services arising in a Contracting State may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner thereofof the fees is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the fees. (3) . The term "“fees for technical services" ” as used in this Article means payments any payment in consideration for any service of any kind to any persona managerial, other than payments technical or consultancy nature, unless the payment is made: a. to an employee of the person making the payments, payment; b. for teaching in consideration an educational institution or for any teaching by an educational institution; or c. by an individual for services for the personal use of a managerial, technical or consultancy naturean individual. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the fees for technical services arise, arise through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated thereinState, and the contract in respect of which the fees for technical services are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case cases the provisions of Article 7 or Article 15, as the case may be, shall apply. (5) Fees . For the purposes of this Article, subject to paragraph 6, fees for technical services shall be deemed to arise in a Contracting State when if the payer is that State itself, a political subdivision, a local authority or a resident of that State. Where, however, State or if the person paying the fees for technical servicesfees, whether he that person 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 obligation to make pay the payments fees was incurred, and the payments such fees are borne by such the permanent establishment or fixed baseestablishment. 6. For the purposes of this Article, then such fees for technical services shall be deemed not to arise in a Contracting State if the payer is a resident of that State and carries on business in which the other Contracting State through a permanent establishment or fixed base is situatedsituated in that other State and such fees are borne by that permanent establishment. (6) 7. Where, by reason of a special relationship between the payer and the beneficial owner of the fees for technical services or between both of them and some other person, the amount of the fees fees, having regard to the services for technical serviceswhich they are paid, exceeds the amount which would have been paid 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 fees shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Convention.Agreement.‌

FEES FOR TECHNICAL SERVICES. (1) . Fees for technical services arising in a Contracting State and paid to an enterprise a resident of the other Contracting State may be taxed in that other State. (2) . However, such fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner thereofof the 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 feesfees for technical services. (3) . The term "fees for technical services" as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the payments, in received as a consideration for the rendering of any services of a managerial, technical or consultancy natureservices including the services of technical or other personnel, but does not include: (a) consideration for any construction, assembly or like project undertaken by the recipient; or (b) consideration which would be income of the recipient chargeable under the head “Income from employment”. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the fees for technical services arise, arise through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, therein and the contract technical services in respect of which the fees for technical services are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 15, as the case may be, shall apply. (5) . Fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or 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 obligation liability to make pay the payments fees for technical services was incurred, and the payments such fees for technical services are borne by such permanent establishment or fixed baseestablishment, then such fees for technical services shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) Where, . Where by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the fees for technical services, services exceeds the amount which would have been paid 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 Convention.

FEES FOR TECHNICAL SERVICES. (1) . Fees for technical services arising in derived from one of the Contracting States by a Contracting State and paid to an enterprise resident of the other Contracting State who is the beneficial owner thereof and is subject to tax in that other State in respect thereof may be taxed in that other State. (2) However, such fees for technical services may also be taxed in the first-mentioned Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner thereof, the tax so charged shall at a rate not exceed 10 exceeding 5 per cent of the gross amount of the such fees. (3) 2. The term "“fees for technical services" ” as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerialtechnical, technical managerial or consultancy nature. (4) 3. The provisions of paragraphs paragraph 1 and 2 shall not apply if the beneficial owner of the fees for technical services, services being a resident of a Contracting State, carries on business in the other Contracting State in which the fees for technical services arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the contract in respect of which the fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case a case, the provisions of Article 7 or Article 15, as the case may be, shall apply. (5) 4. Fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a resident of that State. Where, however, the person paying the fees for technical services, whether he that person 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 obligation to make pay the payments fees for technical services was incurred, and the payments such fees are borne by such permanent establishment or fixed base, then such fees for technical services shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the fees for technical servicesservices paid exceeds, exceeds for whatever reason, the amount which would have been paid 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 ConventionAgreement.

FEES FOR TECHNICAL SERVICES. (1) . Fees for technical services arising in a Contracting State and paid to an enterprise a resident of the other Contracting State may be taxed in that other State. (2) . However, such fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is where the beneficial owner thereofof the 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 fees. (3) The term "fees for technical services" . 3. The term «fees for technical services» as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerialtechnical, technical managerial or consultancy nature. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the fees for technical services arise, arise through a permanent establishment or a fixed base situated therein, or performs in that other State independent personal services from a fixed base situated thereinservices, and the contract in respect of which the fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case a case, the provisions of Article 7 or Article 15, as the case may be, shall apply. (5) . Fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or 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 obligation to make pay the payments fees for technical services was incurred, and the payments such fees for technical services are borne by such permanent establishment or a fixed base, then such fees for technical services shall be deemed to arise in the Contracting State in which the permanent establishment or a fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the fees for technical servicesservices paid exceeds, exceeds for whatever reason, the amount which would have been paid 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 ConventionAgreement.

FEES FOR TECHNICAL SERVICES. (1) . Fees for technical services arising in a Contracting State and paid to an enterprise a resident of the other Contracting State may be taxed in that other State. (2) . However, such fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner thereofof the 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 feesfees for technical services. (3) . The term "fees for technical services" as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the payments, in received as a consideration for the rendering of any services of a managerial, technical or consultancy natureservices including the services of technical or other personnel, but does not include: (a) consideration for any construction, assembly or like project undertaken by the recipient; or (b) consideration which would be income of the recipient chargeable under the head “salary”. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the fees for technical services arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the contract right or property in respect of which the fees for technical services are paid is effectively connected with (a) such permanent establishment or fixed base, or with (b) business activities referred to in subparagraph (c) of paragraph 1 of Article 7. In such case cases the provisions of Article 7 or Article 15, as the case may be, shall apply. (5) . Fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or 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 obligation liability to make pay the payments fees for technical services was incurred, and the payments such fees for technical services are borne by such permanent establishment or fixed base, then such fees for technical services shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) Where, . Where by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the fees for technical services, having regard to the use, right or information for which they are paid, exceeds the amount which would have been paid 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 ConventionAgreement.

FEES FOR TECHNICAL SERVICES. (1) . Fees for technical services arising in a Contracting State and paid to an enterprise of the other Contracting State may be taxed in that other State. (2) . However, such fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner thereof, the tax so charged shall not exceed 10 per cent 15% of the gross amount of the fees. (3) . The term "fees for technical services" as used in this Article means payments any consideration (including any lump sum consideration) for the provision of or rendering of any kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerial, technical or consultancy natureservices (including the provision by the enterprise of the services of technical or other personnel) but does not include consideration for any activities mentioned in sub-para (3) of paragraph 5 or consideration which would be income falling under Article 15 of the Agreement. (4) . The provisions of paragraphs 1 and 2 shall do not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the fees for technical services ariserise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, therein and the contract in respect of which the fees for technical services are paid is effectively connected with with: (a) such permanent establishment or fixed base, or (b) business activities referred to under (c) of paragraph (1) of Article 7. In such case cases the provisions of Article 7 or Article 15, as the case may be, shall apply. (5) . Fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivisionsub-division, a local authority or a resident of that State, and the services are rendered for the said payer or the services are rendered in that State. Where, however, the person paying the fees for technical services, service 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 obligation to make the payments was incurred, and the payments are borne by such permanent establishment or fixed baseestablishment, then such fees for technical services shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) Where, . Where by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the fees for technical services, services exceeds the amount which would have been paid 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 ConventionAgreement.

FEES FOR TECHNICAL SERVICES. (1) . Fees for technical services arising in a Contracting State Party and paid to an enterprise a resident of the other Contracting State Party may be taxed in that other StateParty. (2) . However, such fees for technical services may also be taxed in the Contracting State Party in which they arise and according to the laws of that StateParty, but if the recipient is the beneficial owner thereofof the fees for technical services is a resident of the other Contracting Party, the tax so charged shall not exceed 10 per cent of the gross amount of the feesfees for technical services. (3) . The term "fees for technical services" as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the payments, in received as a consideration for the rendering of any services of a managerial, technical or consultancy natureservices, including the provision of technical services by an enterprise or other personnel, but does not include payments for services to which the provisions of paragraph 1(a) of Article 15, paragraph 1(b) of Article 15 or Article 16 of this Agreement apply. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting StateParty, carries on business in the other Contracting State Party in which the fees for technical services arise, arise through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the contract in respect of which the fees for technical services are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case the provisions of Article 7 or Article 15, as the case may be, shall apply. (5) . Fees for technical services shall be deemed to arise in a Contracting State Party when the payer is that State itself, a political subdivision, a local authority or a resident of that StateParty. Where, however, the person paying the fees for technical services, whether he is a resident of a Contracting State Party or not, has in a Contracting State Party a permanent establishment or a fixed base in connection with which the obligation liability to make pay the payments fees for technical services was incurred, and the payments such fees for technical services are borne by such permanent establishment or fixed base, then such fees for technical services shall be deemed to arise in the State Party in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the fees for technical services, having regard to the services for which they are paid, exceeds the amount which would have been paid 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 StateParty, due regard being had to the other provisions of this Conventionthe Agreement.

FEES FOR TECHNICAL SERVICES. (1) Fees for technical services arising in a Contracting State and paid to an enterprise a resident of the other Contracting State may be taxed in that other State. (2) However, such fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is where the beneficial owner thereofof the fees for tech- nical services is a resident of the other Contracting State, the tax so charged shall not exceed 10 7.5 per cent of the gross amount of the feesfees for technical services. (3) The term "“fees for technical services" ” as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerialtechnical, technical managerial or consultancy nature. (4) The provisions of paragraphs 1 (1) and 2 (2) shall not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the fees for technical services arise, arise through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the contract in respect of which the fees for technical services are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case case, the provisions of Article 7 or Article 15, as the case may be, shall apply. (5) Fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or 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 obligation to make pay the payments fees for technical services was incurred, and the payments such fees for technical services are borne by such permanent establishment or fixed baseestablishment, then such 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, Where by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the fees for technical servicesservices paid exceeds, exceeds for whatever reason, the amount which would have been paid agreed upon by the payer and the beneficial owner in the absence of such a 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 ConventionAgreement.

FEES FOR TECHNICAL SERVICES. (1) . Fees for technical services arising in a Contracting State Party and paid to an enterprise a resident of the other Contracting State Party may be taxed in that other StateParty. (2) . However, such fees for technical services may also be taxed in the Contracting State Party in which they arise and according to the laws of that StateParty, but if the recipient is the beneficial owner thereofof the fees for technical services is a resident of the other Contracting Party, the tax so charged shall not exceed 10 five (5) per cent of the gross amount of the fees. (3) The term "fees for technical services" . 3. The term “fees for technical services” as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerialtechnical, technical managerial or consultancy nature. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting StateParty, carries on business in the other Contracting State Party in which the fees for technical services arise, arise through a permanent establishment situated therein, or performs in that other State Party independent personal services from a fixed base situated therein, and the contract in respect of which the fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 15, as the case may be, shall apply. (5) . Fees for technical services shall be deemed to arise in a Contracting State Party when the payer is that State itself, a political subdivision, a local authority or a resident of that StateParty. Where, however, the person paying the fees for technical services, whether he is a resident of a Contracting State Party or not, has in a Contracting State Party a permanent establishment or a fixed base in connection with which the obligation to make pay the payments fees for technical services was incurred, and the payments such fees for technical services are borne by such permanent establishment or fixed base, then such fees for technical services shall be deemed to arise in the State Party in which the permanent establishment or fixed base is situated. (6) . Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the fees for technical servicesservices paid exceeds, exceeds for whatever reasons, the amount which would have been paid 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 lastmentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting StateParty, due regard being had to the other provisions of this ConventionAgreement.

FEES FOR TECHNICAL SERVICES. (1) . Fees for technical services arising in a Contracting State and paid to an enterprise which are derived by a resident of the other Contracting State may be taxed in that other State. (2) . However, such fees for technical services may also be taxed in the Contracting State in which they arise arise, and according to the laws of that State, but if the recipient is the beneficial owner thereofof the fees for technical services, the tax so charged shall not exceed 10 per cent of the gross amount of the feesfees for technical services. (3) . The term "fees for technical services" as used in this Article means payments payment of any kind to any person, other than payments to an employee of the person making the payments, in consideration for the rendering of any services of a managerial, technical or consultancy natureservices including the provision of services by technical or other personnel but does not include payments for services mentioned in Article 14 and Article 15 of this Agreement. (4) . The provisions of paragraphs paragraph 1 and 2 of this Article shall not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the fees for technical services arise, arise through a permanent establishment situated therein, or performs in that other State independent personal personnel services from a fixed base situated therein, and the contract in respect of which the fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case case, the provisions of Article 7 or Article 1514, as the case may be, shall apply. (5) . Fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or 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 obligation to make pay the payments fees for technical services was incurred, and the payments such fees for technical services are borne by such permanent establishment or fixed base, then such 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 beneficial owner or between both of them and some other person, the amount of the fees for technical servicesservices paid exceeds, exceeds for whatever reason, the amount which would have been paid agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall only apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws law of each Contracting State, due regard being had to the other provisions of this ConventionAgreement.

FEES FOR TECHNICAL SERVICES. (1) . Fees for technical services arising in a Contracting State and paid to an enterprise a resident of the other Contracting State may shall be taxed in that other State. (2) . However, such fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is where the beneficial owner thereof, of the 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 feesfees for technical services. (3) . The term "fees for technical services" as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerialtechnical, technical managerial or consultancy nature. (4) . The provisions of paragraphs paragraph 1 and 2 of this Article shall not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the fees for technical services arise, arise through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated thereinservices, and the contract in respect of which the fees for technical services are paid is effectively connected with such permanent establishment or fixed basesuch services. In such case a case, the provisions of Article 7 or Article 15, as the case may be, shall apply. (5) . Fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or 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 obligation to make pay the payments fees for technical services was incurred, and the payments such fees for technical services are borne by such permanent establishment or fixed baseestablishment, then such 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 beneficial owner or between both of them and some other person, the amount of the fees for technical servicesservices paid exceeds, exceeds for whatever person, the amount which would have been paid 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 law of each Contracting State, due regard being had to the other provisions of this ConventionAgreement.

FEES FOR TECHNICAL SERVICES. (1) . Fees for technical services arising in a Contracting State and paid to an enterprise a resident of the other Contracting State may be taxed in that other State. (2) . However, such fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is where the beneficial owner thereof, of the fees for technical services is a resident of the other Contracting State the tax so charged shall not exceed 10 per cent percent of the gross amount of the fees. (3) The term "fees for technical services" . 3. The term “fees for technical services” as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerialtechnical, technical managerial or consultancy nature. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the fees for technical services arise, arise through a permanent establishment situated therein, or performs in that other State independent personal personnel services from a fixed base situated therein, and the contract in respect of which the fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such a case the provisions of Article 7 or Article 1514, as the case may be, shall apply. (5) . Fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or 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 obligation to make pay the payments fees for technical services was incurred, and the payments such fees for technical services are borne by such permanent establishment or fixed base, then such 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 beneficial owner or between both of them and some other person, the amount of the fees for technical servicesservices paid exceeds, exceeds for whatever reason, the amount which would have been paid 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 law of each Contracting State, due regard being had to the other provisions of this ConventionAgreement.

FEES FOR TECHNICAL SERVICES. (1) . Fees for technical services arising in derived from one of the Contracting States by a Contracting State and paid to an enterprise resident of the other Contracting State who is the beneficial owner thereof and is subject to tax in that other State in respect thereof may be taxed in that other State. (2) However, such fees for technical services may also be taxed in the first-mentioned Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner thereof, the tax so charged shall at a rate not exceed 10 exceeding 5 per cent of the gross amount of the such fees. (3) 2. The term "“fees for technical services" ” as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerialtechnical, technical managerial or consultancy nature. (4) 3. The provisions of paragraphs paragraph 1 and 2 shall not apply if the beneficial owner of the fees for technical services, services being a resident of a Contracting State, carries on business in the other Contracting State in which the fees for technical services arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the contract in respect of which the fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case a case, the provisions of Article 7 or Article 15, as the case may be, shall apply. (5) 4. Fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a resident of that State. Where, however, the person paying the fees for technical services, whether he that person 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 obligation to make pay the payments fees for technical services was incurred, and the payments such fees are borne by such permanent establishment or fixed base, then such fees for technical services shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the fees for technical servicesservices paid exceeds, exceeds for whatever reason, the amount which would have been paid 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-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 Convention.Agreement. Article 14

FEES FOR TECHNICAL SERVICES. (1) . Fees for technical services arising in a Contracting State and paid to an enterprise a resident of the other Contracting State may be taxed in that other State. (2) . However, such fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is where the beneficial owner thereof, of the fees for technical services is a resident of the other Contracting State the tax so charged shall not exceed 10 per cent percent of the gross amount of the feesfees for technical services. (3) . The term "fees for technical services" as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerialtechnical, technical managerial or consultancy nature. (4) . The provisions of paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the fees for technical services arise, arise through a permanent establishment situated therein, or performs in that other State independent personal personnel services from a fixed base situated therein, and the contract in respect of which the fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such a case the provisions of Article 7 or Article 15, as the case may be, shall apply. (5) . Fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or 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 obligation to make pay the payments fees for technical services was incurred, and the payments such fees for technical services are borne by such permanent establishment or fixed base, then such 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 beneficial owner or between both of them and some other person, the amount of the fees for technical servicesservices paid exceeds, exceeds for whatever reason, the amount which would have been paid 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 ConventionAgreement.

FEES FOR TECHNICAL SERVICES. (1) . Fees for technical services arising in a Contracting State and paid to an enterprise a resident of the other Contracting State may be taxed in that other State. (2) . However, such fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner thereof, of the fees for technical services is a resident of the other Contracting State the tax so charged shall not exceed 10 5 per cent of the gross amount of the fees. (3) The term "fees for technical services" . 3. The term “fees for technical services” as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerialtechnical, technical managerial or consultancy nature. (4) . The provisions of paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the fees for technical services arise, arise through a permanent establishment situated therein, or performs in that other State professional services or other activities of an independent personal services character from a fixed base situated thereindeemed permanent establishment, and the contract in respect of which the fees for technical services are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such a case the provisions of Article 7 or Article 15, as the case may be, shall apply. (5) . Fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or 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 obligation to make pay the payments fees for technical services was incurred, and the payments such fees for technical services are borne by such permanent establishment or fixed baseestablishment, then such 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 beneficial owner or between both of them and some other person, the amount of the fees for technical servicesservices paid exceeds, exceeds for whatever reason, the amount which would have been paid 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 last­mentioned 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 ConventionAgreement.

FEES FOR TECHNICAL SERVICES. (1) . Fees for technical services arising in a Contracting State and paid to an enterprise which are derived by a resident of the other Contracting State may be taxed in that other State. (2) . However, such fees for technical services may also be taxed in the Contracting State in which they arise arise, and according to the laws of that State, but if the recipient is the beneficial owner thereofof the 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 feesfees for technical services. (3) . The term "fees for technical services" as used in this Article means payments payment of any kind to any person, other than payments to an employee of the person making the payments, in consideration for the rendering of any services of a managerial, technical or consultancy natureservices, including the provision of technical services by the enterprise or other personnel, but does not include payments for services to which Article 15 of this Agreement applies. (4) . The provisions of paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the fees for technical services arise, arise through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the contract in respect of which the fees for technical services are paid is effectively connected with such permanent establishment or fixed baseestablishment. In such case case, the provisions of Article 7 or Article 15, as the case may be, shall apply. (5) . Fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a resident of that State and such services are exercised within 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 obligation to make pay the payments fees for technical services was incurred, and the payments such fees for technical services are borne by such permanent establishment or fixed base, then such 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 beneficial owner or between both of them and some other person, the amount of the fees for technical servicesservices paid exceeds, exceeds for whatever reason, the amount which would have been paid agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall only 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 ConventionAgreement.

FEES FOR TECHNICAL SERVICES. (1) . Fees for technical services arising in a Contracting State and paid to an enterprise a resident of the other Contracting State may be taxed in that other State. (2) . However, such fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is where the beneficial owner thereof, of the 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 fees. (3) The term "fees for technical services" . 3. The term “fees for technical services” as used in this Article means payments payment of any kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerialtechnical, technical managerial or consultancy nature. (4) . The provisions provision of paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting State, carries on business in on the other Contracting State in which the fees for technical services arise, arise through a permanent establishment situated therein, or performs in that other State independent personal personnel services from a fixed base situated therein, and the contract in respect of which the fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such a case the provisions of Article 7 or Article 1514, as the case may be, shall apply. (5) . Fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or 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 obligation to make pay the payments fees for technical services was incurred, and the payments such fees for technical services are borne by such permanent establishment or fixed base, then such 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 beneficial owner or between both of them and some other person, the amount of the fees for technical servicesservices paid exceeds, exceeds for whatever reason, the amount which would have been paid 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 law of each Contracting State, due regard being had to the other provisions of this ConventionAgreement.

FEES FOR TECHNICAL SERVICES. (1) . Fees for technical services arising in a Contracting State and paid to an enterprise which are derived by a resident of the other Contracting State may be taxed in that other State. (2) . However, such fees for technical services may also be taxed in the Contracting State in which they arise arise, and according to the laws of that State, but if the recipient is the beneficial owner thereofof the fees for technical services, the tax so charged shall not exceed 10 per cent of the gross amount of the feesfees for technical services. (3) . The term "fees for technical services" as used in this Article means payments payment of any kind to any person, other than payments to an employee of the person making the payments, in consideration for the rendering of any services of a managerial, technical or consultancy natureservices, including the provision by the enterprise of the services of technical or other personnel, but does not include payments for services to which Article 16 of this Agreement applies. (4) . The provisions of paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the fees for technical services arise, arise through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the contract in respect of which the fees for technical services are paid is effectively connected with (a) such permanent establishment establishment, or fixed basewith (b) business activities referred to in (c) of paragraph 1 of Article 7. In such case case, the provisions of Article 7 or Article 15, as the case may be, shall apply. (5) . Fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or 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 obligation to make pay the payments fees for technical services was incurred, and the payments such fees for technical services are borne by such permanent establishment or fixed base, then such 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 beneficial owner or between both of them and some other person, the amount of the fees for technical servicesservices paid exceeds, exceeds for whatever reason, the amount which would have been paid agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall only apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws law of each Contracting State, due regard being had to the other provisions of this ConventionAgreement.

FEES FOR TECHNICAL SERVICES. (1) . Fees for technical services arising in a Contracting State and paid to an enterprise a resident of the other Contracting State may be taxed in that other State. (2) . However, such fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is where the beneficial owner thereof, of the fees for technical services is a resident of the other Contracting State the tax so charged shall not exceed 10 8 per cent of the gross amount of the fees. (3) The term "fees for technical services" . 3. The term “fees for technical services” as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerialtechnical, technical managerial or consultancy nature. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the fees for technical services arise, arise through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the contract in respect of which the fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such a case the provisions of Article 7 or Article 15, as the case may be, shall apply. (5) . Fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or 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 obligation to make pay the payments fees for technical services was incurred, and the payments such fees for technical services are borne by such permanent establishment or fixed base, then such 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 beneficial owner or between both of them and some other person, the amount of the fees for technical servicesservices paid exceeds, exceeds for whatever reason, the amount which would have been paid 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 law of each Contracting State, due regard being had to the other provisions of this ConventionAgreement.

FEES FOR TECHNICAL SERVICES. (1) . Fees for technical services arising in a Contracting State and paid to an enterprise a resident of the other Contracting State may be taxed in that other State. (2) . However, such fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is where the beneficial owner thereof, of the 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 feesfees for technical services. (3) . The term "fees for technical services" as used in this Article means payments payment of any kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerialtechnical, technical managerial or consultancy nature. (4) . The provisions provision of paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting State, carries on business in on the other Contracting State in which the fees for technical services arise, arise through a permanent establishment situated therein, or performs in that other State independent personal personnel services from a fixed base situated therein, and the contract in respect of which the fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such a case the provisions of Article 7 or Article 1514, as the case may be, shall apply. (5) . Fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a statutory body thereof, or 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 obligation to make pay the payments fees for technical services was incurred, and the payments such fees for technical services are borne by such permanent establishment or fixed base, then such 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 beneficial owner or between both of them and some other person, the amount of the fees for technical servicesservices paid exceeds, exceeds for whatever reason, the amount which would have been paid 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-last- mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws law of each Contracting State, due regard being had to the other provisions of this ConventionAgreement.

FEES FOR TECHNICAL SERVICES. (1) . Fees for technical services arising in a Contracting State and paid to an enterprise a resident of the other Contracting State may be taxed in that other State. (2) . However, such fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner thereof, of the fees for technical services is a resident of the other Contracting State the tax so charged shall not exceed 10 ten (10) per cent of the gross amount of the fees. (3) The term "fees for technical services" . 3. The term “fees for technical services” as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerialtechnical, technical managerial or consultancy nature, but does not include payments for services to which Article 15 of this Agreement applies. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the fees for technical services arise, arise through a permanent establishment situated therein, therein or performs in that other State independent personal personnel services from a fixed base situated therein, and the contract in respect of which the fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such a case the provisions of Article 7 or Article 15, as the case may be, shall apply. (5) . Fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or 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 obligation to make pay the payments fees for technical services was incurred, and the payments such fees for technical services are borne by such permanent establishment or fixed base, then such 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 beneficial owner or between both of them and some other person, the amount of the fees for technical servicesservices paid exceeds, exceeds for whatever reason, the amount which would have been paid 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 law of each Contracting State, due regard being had to the other provisions of this ConventionAgreement.

FEES FOR TECHNICAL SERVICES. (1) . Fees for technical services arising in a Contracting State and paid to an enterprise of the other Contracting State may be taxed in that other State. (2) . However, such fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner thereof, the tax so charged shall not exceed 10 15 per cent of the gross amount of the fees. (3) . The term "fees for technical services" as used in this Article means payments any consideration (including any lump sum consideration) for the provision of or rendering of any kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerial, technical or consultancy natureservices (including the provision by the enterprise of the services of technical or other personnel) but does not include consideration for any activities mentioned in sub-para (3) of paragraph 5 or consideration which would be income falling under Article 15 of the Agreement. (4) . The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the fees for technical services, services being a resident of a Contracting State, carries on business in the other Contracting State in which the fees for technical services arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, therein and the contract in respect of which the fees for technical services are paid is effectively connected with with: (a) such permanent establishment or fixed base, or (b) business activities referred to under (c) of paragraph (1) of Article 7. In such case cases the provisions of Article 7 or Article 15, as the case may be, shall apply. (5) Fees . Fee for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivisionsub-division, a local authority or a resident of that State, and the services are rendered for the said payer or the services are rendered in that State. Where, however, the person paying the fees for technical services, services whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base base, in connection with which the obligation to make the payments was incurred, and the payments are borne by such permanent establishment or fixed baseestablishment, then such fees for technical services shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. (6) Where, . Where by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the fees for technical services, services exceeds the amount which would have been paid 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 ConventionAgreement.

FEES FOR TECHNICAL SERVICES. (1) . Fees for technical services arising in derived from one of the Contracting States by a Contracting State and paid to an enterprise resident of the other Contracting State who is the beneficial owner thereof and is subject to tax in that other Contracting State in respect thereof may be taxed in that other State. (2) However, such fees for technical services may also be taxed in the first-mentioned Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner thereof, the tax so charged shall at a rate not exceed 10 exceeding 15 per cent of the gross amount of the technique fees. (3) 2. The term "«fees for technical services" » as used in this Article means payments of any kind to any person, other than payments to an employee of the person making the payments, in consideration for any services of a managerialtechnical, technical managerial or consultancy nature. (4) 3. The provisions of paragraphs paragraph 1 and 2 of this Article shall not apply if the beneficial owner of the fees for technical services, being a resident of a Contracting State, carries on business in the other Contracting State in which the fees for technical services arise, arise through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated thereinservices, and the contract in respect of which the fees for technical services are paid is effectively connected with such permanent establishment or fixed basesuch services. In such case a case, the provisions of Article 7 or Article 1515 of this Agreement, as the case may be, shall apply. (5) 4. Fees for technical services shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a resident of that Contracting 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 obligation to make pay the payments fees for technical services was incurredincluded, and the payments such fees for technical services are borne by such permanent establishment or fixed baseestablishment, then such technical fees for technical services shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. (6) 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the fees for technical servicesservices paid exceeds, exceeds for whatever reason, the amount which would have been paid 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 ConventionAgreement.