FEES FOR TECHNICAL SERVICES. Notwithstanding the provisions of Article 15, fees for technical services arising in a Contracting State and paid to a 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 the first-mentioned State at a rate not exceeding 10 per cent of the gross amount of the fees for the technical services.
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Samples: Double Taxation Avoidance Agreement, Double Taxation Avoidance Agreement, Double Taxation Avoidance Agreement