Common use of TECHNICAL FEES Clause in Contracts

TECHNICAL FEES. 1. Technical fees derived from one of the Contracting States by 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 Contracting State at a rate not exceeding 10 per cent of the gross amount of the technical fees. 2. The term " technical fees " as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 3. The provisions of paragraph 1 of this Article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, or performs in that other State independent personal services, and the technical fees are effectively connected with such permanent establishment or such services. In such case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 4. Technical fees shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority thereof, or a resident of that State. Where, however, the person paying the technical fees, whether he is a resident of the Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other persons, the amount of the technical fees paid exceeds, for what ever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

TECHNICAL FEES. 1. Technical fees derived from one of the arising in a Contracting States by 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 that other State. 2. However, such technical fees may also be taxed in the first-mentioned Contracting State at in which they arise and according to the law of that State, but where the beneficial owner of the technical fees is a rate resident of the other Contracting State the tax so charged shall not exceeding 10 per cent exceed 10% of the gross amount of the technical fees. 23. The term " "technical fees fees" as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 34. The provisions of paragraph paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, or performs in that other State independent personal services, and the technical fees are effectively connected with such permanent establishment or such services. In such case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 45. Technical fees 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 technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- 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 Agreement.

TECHNICAL FEES. 1. Technical fees derived from one of the Contracting States by 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 Contracting State at a rate not exceeding 10 15 per cent of the gross amount of the technical fees. 2. The term " "technical fees fees" as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 3. The provisions of paragraph 1 (1) of this Article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, or performs in that other State independent personal services, and the technical fees are effectively connected with such permanent establishment or such services. In such case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 4. Technical fees 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 technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws law of each Contracting State, due regard being had to the other provisions of this Agreement.

TECHNICAL FEES. 1. Technical fees derived derives from one of the Contracting States State by a 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 the first-mentioned Contracting State at a rate not exceeding 10 per cent of the gross amount of the technical fees. 2. The term " "technical fees fees" as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 3. The provisions of paragraph 1 of this Article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, or performs in that other Contracting State independent personal services, and the technical fees are effectively connected with such permanent establishment or such services. In such case, the provisions of Article 7 or Article 1514, as the case may be, shall apply. 4. Technical fees shall be deemed to arise in a Contracting State when the payer is that Contracting State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that Contracting State. Where, however, the person paying the technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- 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 Agreement.

TECHNICAL FEES. 1. Technical fees derived from one of the a Contracting States State by 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 Contracting State at a rate not exceeding 10 15 per cent of the gross amount of the technical fees. 2. The term " "technical fees fees" as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a scientific, technical, industrial, commercial, managerial or consultancy nature. 3. The provisions of paragraph 1 (1) of this Article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, or performs in that other State independent personal services, and the technical fees are effectively connected with such permanent establishment or such services. In such case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 4. Technical fees 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 technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- mentioned lastmentioned 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 Agreement.

TECHNICAL FEES. 1. Technical fees derived from one arising in a Contracting State which are paid to a resident of the other Contracting States by State may be taxed in that other State. 2. However, such technical fees may also be taxed in the Contracting State in which they arise, and according to the law of that State, but where such technical fees are 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 thereof, the tax charged in the first-mentioned Contracting State at a rate in which the technical fees arise shall not exceeding 10 exceed 7.5 per cent of the gross amount of the technical such fees. 23. The term " “technical fees " fees” as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a an administrative, technical, managerial or consultancy nature. 34. The provisions of paragraph paragraphs 1 and 2 of this Article shall not apply if the beneficial owner recipient of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services, therein and the technical fees are effectively connected with such permanent establishment or such servicesestablishment. In such case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 45. Technical fees shall be deemed to arise in a Contracting State when the payer is that State itselfState, a political subdivision, or a local authority thereof, thereof or a resident of that State. Where, however, the person paying the technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such that permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner recipient or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner recipient 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 Agreement. 7. Notwithstanding paragraph 2, where, in any Agreement for the avoidance of double taxation and the prevention of fiscal evasion entered into by Botswana with any State other than Ireland after the signing of this Agreement, the rate of tax specified in the Article relating to technical fees is a rate less than 7.5 per cent, such lower rate shall apply as if it had been the rate specified in this Article.

TECHNICAL FEES. 1. Technical fees derived from one of the Contracting States by 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 Contracting State at a rate not exceeding 10 per cent of the gross amount of the technical fees. 2. The term " "technical fees fees" as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 3. The provisions of paragraph 1 of this Article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, or performs in that other State independent personal services, and the technical fees are effectively connected with such permanent establishment or such services. In such case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 4. Technical fees 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 technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws law of each Contracting State, due regard being had to the other provisions of this Agreement.

TECHNICAL FEES. 1. Technical fees derived from one of the arising in a Contracting States by 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 that other State. 2. However, such technical fees may also be taxed in the first-mentioned Contracting State at in which they arise and according to the laws of that State, but if the beneficial owner of the technical fees is a rate resident of the other Contracting State, the tax so charged shall not exceeding 10 exceed 7.5 per cent of the gross amount of the technical fees. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation. 23. The term " “technical fees " fees” as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services service of a technical, managerial or consultancy nature. 34. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, or performs in that other State independent personal services, therein and the technical fees are effectively connected with such permanent establishment or such servicesestablishment. In such case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 45. Technical fees shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority thereof, or a resident of that State. Where, however, the person paying the technical fees, whether he that person is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever reason, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- 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 Agreement.

TECHNICAL FEES. 1. Technical fees derived from one arising in a Contracting State which are paid to a resident of the other Contracting States by State may be taxed in that other State, 2. However, such technical fees may also be taxed in the Contracting State in which they arise, and according to the law of that State, but where such technical fees are 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 thereof, the tax charged in the first-mentioned Contracting State at a rate in which the technical fees arise shall not exceeding 10 exceed 7.5 per cent of the gross amount of the technical such fees. 23. The term " "technical fees " fees” as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a an administrative, technical, managerial or consultancy nature. 34. The provisions of paragraph paragraphs 1 and 2 of this Article shall not apply if the beneficial owner recipient of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services, therein and the technical fees are effectively connected with such permanent establishment or such servicesestablishment. In such case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 45. Technical fees shall be deemed to arise in a Contracting State when the payer is that State itselfState, a political subdivision, or a local authority thereof, thereof or a resident of that State. Where, however, the person paying the technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such that permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated., 56. Where, by reason of a special relationship between the payer and the beneficial owner recipient or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner recipient 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 Agreement. 7. Notwithstanding paragraph 2, where, in any Agreement for the avoidance of double taxation and the prevention of fiscal evasion entered into by Botswana with any State other than Ireland after the signing of this Agreement, the rate of tax specified in the Article relating to technical fees is a rate less than 7.5 per cent, such lower rate shall apply as if it had been the rate specified in this Article.

TECHNICAL FEES. 1. Technical fees derived from one of the Contracting States by 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 Contracting State at a rate not exceeding 10 per cent of the gross amount of the technical fees. 2. The term " "technical fees fees" as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 3. The provisions of paragraph 1 of this Article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, or performs in that other State independent personal services, and the technical fees are effectively connected with such permanent establishment or such services. In such a case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 4. Technical fees 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 technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article 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 Agreement.

TECHNICAL FEES. 1. Technical fees derived from one of the Contracting States by 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 Contracting State at a rate not exceeding 10 per cent of the gross amount of the technical fees. 2. The term " "technical fees fees" as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 3. The provisions of paragraph 1 of this Article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, or performs in that other State independent personal services, and the technical fees are effectively connected with such permanent establishment or such services. In such case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 4. Technical fees 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 technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- last-mentioned amount. In such a 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 Agreement.

TECHNICAL FEES. 1. Technical fees derived from one of the arising in a Contracting States by State and paid to a resident of the other Contracting State who may be taxed in that other State. 2. However, such technical fees 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 and is subject to of the technical fees the tax in that other State in respect thereof may be taxed in the first-mentioned Contracting State at a rate so charged shall not exceeding exceed 10 per cent of the gross amount of the technical fees. 23. The term " “technical fees " fees” as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 34. The provisions of paragraph paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, or performs in that other State independent personal servicesservices from a fixed base situated therein, and the technical fees are effectively connected with (a) such permanent establishment or such servicesfixed base or with (b) business activities referred to under (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. 45. Technical fees shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority thereof, or a resident of that State. Where, however, the person paying the technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such permanent establishmentestablishment or fixed base, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- 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 Agreement.

TECHNICAL FEES. 1. Technical fees derived from one of the Contracting States by 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 Contracting State at a rate not exceeding 10 per cent of the gross amount of the technical fees. 2. The term " "technical fees fees" as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 3. The provisions of paragraph 1 of this Article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, or performs in that other State independent personal services, and the technical fees are effectively connected with such permanent establishment or such services. In such a case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 4. Technical fees 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 technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such permanent establishment, establishment then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other persons, the amount of the technical fees paid exceeds, for what ever reasonperson, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- mentioned amount. In such a 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 Agreement.

TECHNICAL FEES. 1. Technical fees arising in a Contracting State which are derived from one of the Contracting States by 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 that other Contracting State. 2. However, such technical fees may also be taxed in the first-mentioned Contracting State at in which they arise and according to the laws of that State, but if the beneficial owner of the technical fees is a rate resident of the other Contracting State, the tax so charged shall not exceeding 10 exceed ten per cent of the gross amount of the technical fees. 23. The term " “technical fees " fees” as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 34. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise arise, through a permanent establishment situated therein, or performs in that other State independent personal servicesservices from a fixed base situated therein, and the technical fees are effectively connected with a) such permanent establishment or such servicesfixed base, or with b) business activities referred to in sub-paragraph c) of paragraph 1 of Article 7. In such casecases, the provisions of Article 7 or Article 15, as the case may be, shall apply. 45. Technical fees shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority thereof, or a resident of that State. Where, however, the person paying the technical fees, whether he is a resident of the 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 pay the technical fees was incurred, and such technical fees are borne by such permanent establishmentestablishment or fixed base, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner of the technical fees or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner of the technical fees in the absence of such relationship, the provisions of this Article shall apply only to the last- last-mentioned amountamount of technical fees. 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 Agreement. 7. The provisions of this Article shall not apply if it was the main purpose or one of the main purposes of any person concerned with the creation or assignment of the rights in respect of which the technical fees are paid to take advantage of this Article by means of that creation or assignment.

TECHNICAL FEES. 1. Technical fees derived from one of the fee's arising in a Contracting States by 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 that other State. 2. However, such technical fees may also be taxed in the first-mentioned Contracting State at in which they arise and according to the law of that State; but where the beneficial owner of the technical fees is a rate resident of the other Contracting State the tax so charged shall not exceeding exceed 10 per cent of the gross amount of the technical fees. 23. The term " "technical fees fees" as used in this Article means payments of any kind to any person, other than to an employee of the person making the paymentspayment, in consideration for any services of a technical, managerial or consultancy nature. 34. The provisions of paragraph 1 of this Article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State, carries on business in the other Contracting State in which the technical fees arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services, and the technical fees are effectively connected with such permanent establishment or such servicesestablishment. In such case, case the provisions of Article 7 or Article 15, as the case may beof this Agreement, shall apply. 45. The provision of paragraph 1 also shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, performs in that other State independent personal services covered under Article 14. In such case the provisions of Article 14 of this Agreement shall apply. 6. Technical fees shall be deemed to arise in a Contracting State when where 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 technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 57. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

TECHNICAL FEES. 1. Technical fees derived from one of the Contracting States by 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 firstmentioned Contracting State at a rate not exceeding 10 per cent of the gross amount amounts of the technical fees. 2. The term " "technical fees fees" as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 3. The provisions of paragraph paragraphs 1 of this Article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, or performs in that other State independent independents personal services, and the technical fees are effectively connected with such permanent establishment or such services. In such case, case the provisions of Article 7 or Article 15, as the case may be, shall apply. 4. Technical fees shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority thereof, or a resident of that State. Where, however, the person paying the technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- 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 Agreement.

TECHNICAL FEES. 1. Technical fees derived from one of the arising in a Contracting States by State and paid to a resident of the other Contracting State who may be taxed in that other State. 2. However, such technical fees 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 and is subject to of the technical fees the tax in that other State in respect thereof may be taxed in the first-mentioned Contracting State at a rate so charged shall not exceeding 10 exceed 7.5 per cent of the gross amount amounts of the technical fees. 23. The term " “technical fees " fees” as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 34. The provisions of paragraph paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise through thorough a permanent establishment situated therein, or performs in that other State independent personal services, and the technical fees are effectively connected with (a) such permanent establishment or such servicesfixed base or with (b) business activities referred to under subparagraph (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. 45. Technical fees shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority thereof, or a resident of that State. Where, however, the person paying the technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- 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 Agreement.

TECHNICAL FEES. 1. Technical fees derived from one of the Contracting States by 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 Contracting State at a rate not exceeding 10 per cent of the gross amount of the technical fees. 2. The term " technical fees " as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 3. The provisions of paragraph 1 of this Article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, or performs in that other State independent personal services, and the technical fees are effectively connected with such permanent establishment or such services. In such a case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 4. Technical fees 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 technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurredincurred , and such technical fees are borne by such permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- 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 Agreement.

TECHNICAL FEES. 1. Technical fees arising in a Contracting State which are derived from one of the Contracting States by 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 that other State. 2. However, such technical fees may also be taxed in the first-mentioned Contracting State at in which they arise, and according to the laws of that State; but if the recipient is a rate beneficial owner of the technical fees, the tax so charged shall not exceeding exceed 10 per cent of the gross amount of the technical fees. 23. The term " “technical fees " fees” as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 34. The provisions of paragraph 1 and 2 of this Article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, or performs in that other State independent personal services, and the technical fees are effectively connected with such permanent establishment or such services. In such case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 45. Technical fees 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 technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such that permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner recipient or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- mentioned lastmentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, State due regard being had to the other provisions of this Agreement.

TECHNICAL FEES. 1. Technical fees derived from one of the a Contracting States State by 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 on the first-mentioned Contracting State at a rate not exceeding 10 per cent of the gross amount of the technical fees. 2. The term " "technical fees fees" as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 3. The provisions of paragraph 1 of this Article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, or performs in that other State independent personal services, and the technical fees are effectively connected with such permanent establishment or such services. In such a case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 4. Technical fees shall be deemed to arise in a Contracting State when the payer is that Contracting State itself, a political subdivision, a local authority thereof, or a resident of that State. Where, however, the person paying the technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws law of each Contracting State, due regard being had to the other provisions of this Agreement.

TECHNICAL FEES. 1. Technical fees arising in a Contracting State which are derived from one of the Contracting States by a resident of the other Contracting State who may be taxed in that other Contracting State. 2. However, such technical fees 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 thereof and is subject to of the technical fees, the tax in that other State in respect thereof may be taxed in the first-mentioned Contracting State at a rate so charged shall not exceeding 10 exceed 15 per cent cent. of the gross amount of the technical fees. 23. The term " "technical fees fees" as used in this Article article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 34. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, State carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, or performs in that other Contracting State independent personal services, services from a fixed base situated therein and the technical fees are effectively connected with such permanent establishment or such servicesfixed base. In such case, the provisions of Article 7 or Article 1516, as the case may be, shall apply. 45. Technical fees shall be deemed to arise in a Contracting State when the payer is that Contracting State itself, a political subdivisionsub-division, a local authority thereofauthority, or a resident of that Contracting State. WhereHowever, however, where the person paying the technical fees, whether he is a resident of the that Contracting State or not, has in a that Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to pay the technical fees was incurred, and such technical fees are borne by such permanent establishment, establishment or fixed base then such the technical fees shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article the 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 Agreement.

TECHNICAL FEES. 1. Technical fees derived from one of the Contracting States by 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 Contracting State at a rate not exceeding 10 5 per cent of the gross amount of the technical fees. 2. The term " "technical fees fees" as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for of any services of a technical, managerial or consultancy nature. 3. The provisions of paragraph 1 of this Article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, or performs in that other State independent personal services, and the technical fees are effectively connected with such permanent establishment or such services. In such case, the provisions of Article 7 or Article 1514, as the case may be, shall apply. 4. Technical fees 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 technical fees, whether he is a resident of the Contracting a Contacting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such permanent establishment, then such technical fees shall be deemed to arise in the Contracting State States in which the permanent establishment is situated. 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws law of each Contracting State, due regard being had to the other provisions of this Agreement.

TECHNICAL FEES. 1. Technical Notwithstanding the provisions of Article 15, technical fees derived from one of the Contracting States by 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 Contracting State at a rate not exceeding 10 per cent of the gross amount of the technical fees. 2. The term " "technical fees fees" as used in this Article means payments payment of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 3. The provisions provision of paragraph 1 of this Article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, or performs in that other State independent personal personnel services, and the technical fees are effectively connected with such permanent establishment or such services. In such case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 4. Technical fees shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority thereof, or a resident of that State. Where, however, the person paying the technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees fee was incurred, and such technical fees are borne by such permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall only 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 Agreement.

TECHNICAL FEES. 1. Technical The technical fees arising in a Contracting State which are derived from one of the Contracting States by 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 that other State. 2. However, such technical fees may also be taxed in the first-mentioned Contracting State at in which they arise, and according to the laws of that State, but where the beneficial owner of such technical fees is a rate resident of the other Contracting State, the tax so charged shall not exceeding 10 exceed twelve and one half (12 1/2) per cent of the gross amount of the technical fees. 23. The term " “technical fees " fees” as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, payments in consideration for any services of a technical, managerial or consultancy nature. 34. The provisions of paragraph paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise arise, through a permanent establishment situated therein, or performs in that other State independent personal servicesservices from a fixed base situated therein, and the technical fees are effectively connected with such permanent establishment or such servicesfixed base. In such case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 45. Technical fees shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivisionsub-division, a local authority thereof, or a resident of that State. Where, however, the person paying the technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such permanent establishmentestablishment or fixed base, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- last-mentioned amount. In such that 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 Agreement.

TECHNICAL FEES. 1. Technical fees derived from one of the arising in a Contracting States by State and paid to a resident of the other Contracting State who may be taxed in that other State. 2. However, such technical fees 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 and is subject to of the technical fees, the tax in that other State in respect thereof may be taxed in the first-mentioned Contracting State at a rate so charged shall not exceeding 10 exceed 15 per cent of the gross amount of the technical fees. 23. The term " "technical fees fees" as used in this Article means payments of any kind to any person, person other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 34. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply apply, if the beneficial owner of the technical fees, fees being a resident of a Contracting State, State carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, or performs in that other State independent personal services, services and the technical fees are effectively connected with such permanent establishment or such services. In such case, case the provisions of Article 7 or Article 15, as the case may be, shall apply. 45. Technical fees shall be deemed to arise in a Contracting State when the payer payee 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 technical fees, fees whether he is a resident of the a Contracting State or not, has in a resident of a Contracting State a permanent establishment or a fixed base in connection with which the obligation to pay the technical fees was incurred, incurred and such technical fees are borne by such that permanent establishment, establishment or fixed base then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner owner, or between both of them and some other persons, persons the amount of the technical fees paid exceedspaid, exceeds for what ever reasonwhatever reasons, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- last-mentioned amount. In such case, the excess part of the payments payment shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

TECHNICAL FEES. 1. Technical fees derived from one of the arising in a Contracting States by State and paid to a resident of the other Contracting State who is may be taxed in that other State. 2. However, such technical fees may also be taxed in the Contracting State in which they arise and according to the law of that State, but if the beneficial owner thereof and is subject to tax in that other State in respect thereof may be taxed of the technical fees in the first-mentioned other Contracting State at a rate State, the tax so charged shall not exceeding exceed 10 per cent of the gross amount of the technical fees. 23. The term " "technical fees fees" as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 34. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise arise, through a permanent establishment situated therein, or performs in that other State independent personal servicesservices from a fixed base situated therein, and the technical fees are effectively connected with such permanent establishment or such servicesfixed base. In such case, case the provisions of Article 7 or Article 1514, as the case may be, shall apply. 45. If a resident of a Contracting State, who receives technical fees which arise in the other Contracting State and who is subject to tax in respect thereof in the first-mentioned State, so elects for any year of assessment, the tax chargeable in respect of those technical fees in the State in which they arise shall be calculated as if he had a permanent establishment or a fixed base in the last-mentioned State and as if those technical fees were taxable in accordance with Article 7 or Article 14, as the case may be, as profits attributable to that permanent establishment or fixed base. 6. Technical fees shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivisionsub-division, a local authority thereof, or a resident of that State. Where, however, the person paying the technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such that permanent establishmentestablishment or fixed base, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 57. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- 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 Agreement.

TECHNICAL FEES. 1. Technical fees arising in a Contracting State which are derived from one of the Contracting States by a resident of the other Contracting State who may be taxed in that other State. 2. However, such technical fees 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 and is subject to of the technical fees, the tax in that other State in respect thereof may be taxed in the first-mentioned Contracting State at a rate so charged shall not exceeding exceed 10 per cent of the gross amount of the technical fees. 23. The term " “technical fees " fees” as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 34. The provisions of paragraph 1 of this Article paragraphs (1) and (2) shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, State carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, or performs in that other State independent personal services, and the technical fees are effectively connected with such permanent establishment or such services. In such case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 45. Technical fees 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 technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such that permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner recipient or between both of them and some other personsperson, the amount of the technical fees paid exceedspaid, exceeds for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- 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 Agreement.

TECHNICAL FEES. 1. Technical fees derived from one of the arising in a Contracting States by 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 that other State. 2. However, such technical fees may also be taxed in the first-mentioned Contracting State at in which they arise, and according to the laws of that State, but if the beneficial owner of the technical fees is a rate resident of the other Contracting State, the tax so charged shall not exceeding exceed 10 per cent of the gross amount of the technical fees. 23. The term " “technical fees " fees” as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services service of a technical, managerial or consultancy nature. 34. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services, therein and the technical fees are effectively connected with such permanent establishment or such servicesestablishment. In such case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 45. Technical fees shall be deemed to arise in a Contracting State when where the payer is that State itself, a political subdivision, a local authority thereof, or a resident of that State. Where, however, the person paying the technical fees, whether he that person is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such the permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever reason, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- 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 Agreement.

TECHNICAL FEES. 1. Technical fees derived from one of the Contracting States by 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 Contracting State at a rate not exceeding 10 per cent of the gross amount of the technical fees. 2. The term " “technical fees " fees” as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 3. The provisions of paragraph 1 of this Article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, or performs in that other State independent personal services, and the technical fees are effectively connected with such permanent establishment or such services. In such case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 4. Technical fees shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority thereof, or a resident of that State. Where, however, the person paying the technical fees, whether he is a resident of the Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other persons, the amount of the technical fees paid exceeds, for what ever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- 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 Agreement.

TECHNICAL FEES. 1. Technical fees derived from one of the arising in a Contracting States by State and paid to a resident of the other Contracting State who is may be taxed in that other State. 2. However, such technical fees may also be taxed in the Contracting State in which they arise and according to the law of that State, but if the beneficial owner thereof and is subject to tax in that other State in respect thereof may be taxed of the technical fees in the first-mentioned other Contracting State at a rate State, the tax so charged shall not exceeding exceed 10 per cent of the gross amount of the technical fees. 23. The term " “technical fees " fees” as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 34. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise arise, through a permanent establishment situated therein, or performs in that other State independent personal servicesservices from a fixed base situated therein, and the technical fees are effectively connected with such permanent establishment or such servicesfixed base. In such case, case the provisions of Article 7 or Article 1514, as the case may be, shall apply. 45. If a resident of a Contracting State, who receives technical fees which arise in the other Contracting State and who is subject to tax in respect thereof in the first-mentioned State, so elects for any year of assessment, the tax chargeable in respect of those technical fees in the State in which they arise shall be calculated as if he had a permanent establishment or a fixed base in the last-mentioned State and as if those technical fees were taxable in accordance with Article 7 or Article 14, as the case may be, as profits attributable to that permanent establishment or fixed base. 6. Technical fees shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivisionsub-division, a local authority thereof, or a resident of that State. Where, however, the person paying the technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such that permanent establishmentestablishment or fixed base, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 57. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- 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 Agreement.

TECHNICAL FEES. 1. Technical fees arising in a Contracting State which are derived from one of the Contracting States by a resident of the other Contracting State who may be taxed in that other State. 2. However, such technical fees 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 and is subject to of the technical fees, the tax in that other State in respect thereof may be taxed in the first-mentioned Contracting State at a rate so charged shall not exceeding exceed 10 per cent of the gross amount of the technical fees. 23. The term " "technical fees fees" as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 34. The provisions of paragraph 1 of this Article paragraphs (1) and (2) shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, or performs in that other State independent personal services, and the technical fees are effectively connected with such permanent establishment or such services. In such case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 45. Technical fees 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 technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such that permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner recipient or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws law of each Contracting State, State due regard being had to the other provisions of this Agreement.

TECHNICAL FEES. 1. Technical fees arising in a Contracting State which are derived from one of the Contracting States by 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 that other State. 2. However, such technical fees may also be taxed in the first-mentioned Contracting State at in which they arise, and according to the law of that State; but if the beneficial owner of the technical fees is a rate resident of the other Contracting State the tax so charged shall not exceeding exceed 10 per cent of the adjusted amount of the technical fees. For the purpose of this paragraph, “the adjusted amount” means 70 per cent of the gross amount of the technical fees. 23. The term " “technical fees " fees” as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial supervisory or consultancy nature, including the use of, or the right to use, information concerning industrial, commercial or scientific experience, but it does not include payments made to an employee of the person making the payments for dependent personal services mentioned in Article 16. 34. The provisions of paragraph 1 paragraphs (1) and (2) of this Article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise arise, through a permanent establishment situated therein, or performs in that other State independent personal servicesservices from a fixed base situated therein, and the technical fees are effectively connected with such permanent establishment or such servicesfixed base. In such case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 45. Technical fees shall be deemed to arise in a Contracting State when the payer is the Government of that State itself, or a political subdivision, subdivision thereof or a local authority thereof, or a resident of that State. Where, however, the person paying the technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such that permanent establishmentestablishment or fixed base, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- 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 Agreement.

TECHNICAL FEES. 1. Technical fees derived from one of the arising in a Contracting States by State and paid to a resident of the other Contracting State who may be taxed in that other State. 2. However, such technical fees 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 technical fees and is subject to a resident of the other Contracting State, the tax in that other State in respect thereof may be taxed in the first-mentioned Contracting State at a rate so charged shall not exceeding exceed 10 per cent of the gross amount of the technical fees. 23. The term " “technical fees " fees” as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services service of a an administrative, technical, managerial or consultancy nature. 34. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services, therein and the technical fees are effectively connected with such permanent establishment or such servicesestablishment. In such case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 45. Technical fees shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority thereof, or a resident of that State. Where, however, the person paying the technical fees, whether he that person is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such the permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever reason, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

TECHNICAL FEES. 1. Technical fees derived from one of the arising in a Contracting States by 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 that other State. 2. However, such technical fees may also be taxed in the first-mentioned Contracting State at in which they arise, and according to the laws of that State, but if the beneficial owner of the technical fees is a rate resident of the other Contracting State, the tax so charged shall not exceeding exceed 10 per cent of the gross amount of the technical fees. 23. The term " "technical fees fees" as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services service of a technical, managerial or consultancy nature. 34. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services, therein and the technical fees are effectively connected with such permanent establishment or such services. In such case, the provisions of Article 7 or Article 15, as the case may be, shall apply.connected 45. Technical fees shall be deemed to arise in a Contracting State when where the payer is that State itself, a political subdivision, a local authority thereof, or a resident of that State. Where, however, the person paying the technical fees, whether he that person is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such the permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever reason, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- 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 Agreement.

TECHNICAL FEES. 1. Technical fees arising in a Contracting State which are derived from one of the Contracting States by a resident of the other Contracting State who may be taxed in that other Contracting State. 2. However, such technical fees 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 thereof and is subject to of the technical fees, the tax in that other State in respect thereof may be taxed in the first-mentioned Contracting State at a rate so charged shall not exceeding 10 exceed 15 per cent of the gross amount of the technical fees. 23. The term " “technical fees " fees” as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 34. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, State carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, or performs in that other Contracting State independent personal services, services from a fixed base situated therein and the technical fees are effectively connected with such permanent establishment or such servicesfixed base. In such case, the provisions of Article 7 or Article 1516, as the case may be, shall apply. 45. Technical fees shall be deemed to arise in a Contracting State when the payer is that Contracting State itself, a political subdivision, a local authority thereofauthority, or a resident of that Contracting State. WhereHowever, however, where the person paying the technical fees, whether he is a resident of the that Contracting State or not, has in a that Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to pay the technical fees was incurred, and such technical fees are borne by such permanent establishment, establishment or fixed base then such the technical fees shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this the 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 Agreement.

TECHNICAL FEES. 1. Technical fees derived from one of the arising in a Contracting States by State and paid to a resident of the other Contracting State who may be taxed in that other State. 2. However, such technical fees 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 technical fees and is subject to a resident of the other Contracting State, the tax in that other State in respect thereof may be taxed in the first-mentioned Contracting State at a rate so charged shall not exceeding exceed 10 per cent of the gross amount of the technical fees. 23. The term " “technical fees " fees” as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services service of a an administrative, technical, managerial or consultancy nature. 34. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services, therein and the technical fees are effectively connected with such permanent establishment or such servicesestablishment. In such case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 45. Technical fees shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority thereof, or a resident of that State. Where, however, the person paying the technical fees, whether he that person is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such the permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever reason, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- 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 Agreement.

TECHNICAL FEES. 1. Technical fees derived from one of the a Contracting States State by 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 Contracting State at a rate not exceeding 10 15 per cent of the gross amount of the technical fees. 2. The term " “technical fees " fees” as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a scientific, technical, industrial, commercial, managerial or consultancy nature. 3. The provisions of paragraph 1 (1) of this Article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, or performs in that other State independent personal services, and the technical fees are effectively connected with such permanent establishment or such services. In such case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 4. Technical fees 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 technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- 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 Agreement.

TECHNICAL FEES. 1. Technical fees derived from one of the arising in a Contracting States by State and paid to a resident of the other Contracting State who may be taxed in that other State. 2. However, such technical fees 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 and is subject to of the technical fees the tax in that other State in respect thereof may be taxed in the first-mentioned Contracting State at a rate shall not exceeding 10 exceed 8 per cent of the gross amount of the technical fees. 23. The term " “technical fees " fees” as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 34. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise arise, through a permanent establishment situated therein, or performs in that other State independent personal servicesservices from a fixed base situated therein, and the technical fees are effectively connected with such permanent establishment or such servicesfixed base. In such case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 45. Technical fees 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 technical fees, whether he the person is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such that permanent establishmentestablishment or fixed base, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- 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 Agreement.

TECHNICAL FEES. 1. Technical fees arising in a Contracting State which are derived from one of the Contracting States by a resident of the other Contracting State who may be taxed in that other Contracting State. 2. However, such technical fees 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 thereof and is subject to of the technical fees, the tax in that other State in respect thereof may be taxed in the first-mentioned Contracting State at a rate so charged shall not exceeding 10 exceed 15 per cent of the gross amount of the technical fees. 23. The term " "technical fees fees" as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 34. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, State carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, or performs in that other Contracting State independent personal services, services from a fixed base situated therein and the technical fees are effectively connected with such permanent establishment or such servicesfixed base. In such case, the provisions of Article 7 or Article 1516, as the case may be, shall apply. 45. Technical fees shall be deemed to arise in a Contracting State when the payer is that Contracting State itself, a political subdivisionsub-division, a local authority thereofauthority, or a resident of that the Contracting State. WhereHowever, however, where the person paying the technical fees, whether he is a resident of the that Contracting State or not, has in a that Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to pay the technical fees was incurred, and such technical fees are borne by such permanent establishment, establishment or fixed base then such the technical fees shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this the 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 Agreement.

TECHNICAL FEES. 1. Technical fees arising in a Contracting State which are derived from one of the Contracting States by 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 Contracting State at a rate not exceeding 10 per cent of the gross amount of the technical feesthat other State. 2. However, such technical fees may also be taxed in the Contracting State in which they arise, and according to the law of that State; but where such technical fees are derived by a resident of the other 3. The term " “technical fees " fees” as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a an administrative, technical, managerial or consultancy naturenature performed outside that State. 34. The provisions of paragraph 1 paragraphs (1) and (2) of this Article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise arise, through a permanent establishment situated therein, or performs in that other State independent personal servicesservices from a fixed base situated therein, and the technical fees are effectively connected with such permanent establishment or such servicesfixed base. In such a case, the provisions of Article 7 or Article 1514, as the case may be, shall apply. 45. Technical fees shall be deemed to arise in a Contracting State when the payer is that State itselfState, a political subdivision, a local authority, a public authority thereof, or a resident of that State. Where, however, the person paying the technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment or fixed base in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such that permanent establishmentestablishment or fixed base, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, Where by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- 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 Agreement.

TECHNICAL FEES. 1. Technical fees derived from one of the arising in a Contracting States by 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-first mentioned Contracting State at a rate State. The tax so charged shall not exceeding 10 per cent exceed 7.5 percent of the gross amount of the technical fees. 2. The term " “technical fees " fees” as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 3. The provisions of paragraph 1 of this Article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, or performs in that other State independent personal services, and the technical fees are effectively connected with such permanent establishment or such services. In such case, case the provisions of Article 7 or Article 15, as the case may be, shall apply. 4. Technical fees shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority thereof, or a resident of that State. Where, however, the person paying the technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such permanent establishmentestablishment or fixed base, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner ow'ner 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 Agreement.

TECHNICAL FEES. 1. Technical fees derived from one of the a Contracting States State by 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 Contracting State at a rate not exceeding 10 15 per cent of the gross amount of the technical fees. 2. The term " technical fees " as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a scientific, technical, industrial, commercial, managerial or consultancy nature. 3. The provisions of paragraph 1 (1) of this Article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, or performs in that other State independent personal services, and the technical fees are effectively connected with such permanent establishment or such services. In such case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 4. Technical fees 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 technical fees, whether he is a resident of the a Contracting State or not, not has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws law of each Contracting State, due regard being had to the other provisions of this Agreement.

TECHNICAL FEES. ‌ (1. ) Technical fees arising in a Contracting State which are derived from one of the Contracting States by 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 that other State. (2) However, such technical fees may also be taxed in the first-mentioned Contracting State at in which they arise, and according to the law of that State, but where the beneficial owner of such technical fees is a rate resident of the other Contracting State the tax so charged shall not exceeding 10 exceed 12½ per cent of the gross amount of the technical fees. 2. (3) The term " "technical fees fees" as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 3. (4) The provisions of paragraph 1 paragraphs (1) and (2) of this Article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise arise, through a permanent establishment situated therein, or performs in that other State independent personal servicesservices from a fixed base situated therein, and the technical fees are effectively connected with such permanent establishment or such servicesfixed base. In such case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 4. (5) Technical fees shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority thereof, or a resident of that State. Where, however, the person paying the technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such that permanent establishmentestablishment or fixed base, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 5. (6) Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- 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 AgreementConvention.

TECHNICAL FEES. (1. ) Technical fees arising in a Contracting State which are derived from one of the Contracting States by 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 that other State. (2) However, such technical fees may also be taxed in the first-mentioned Contracting State at in which they arise, and according to the laws of that State; but if the recipient is a rate beneficial owner of the technical fees, the tax so charged shall not exceeding exceed 10 per cent of the gross amount of the technical fees. 2. (3) The term " 'technical fees " fees' as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 3. (4) The provisions of paragraph 1 and 2 of this Article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, or performs in that other State independent personal services, and the technical fees are effectively connected with such permanent establishment or such services. In such case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 4. (5) Technical fees 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 technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such that permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 5. (6) Where, by reason of a special relationship between the payer and the beneficial owner recipient or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- 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 Agreement.

TECHNICAL FEES. 1. Technical fees arising in a Contracting State which are derived from one of the Contracting States by 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 that other Contracting State. 2. However, such payments may also be taxed in the first-mentioned Contracting State at in which they arise and according to the laws of that Contracting State, but if the beneficial owner of the technical fees is a rate resident of the other Contracting State, the tax so charged shall not exceeding 10 exceed ten per cent of the gross amount of the technical fees. 23. The term " “technical fees " fees” as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 34. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, or performs in that other Contracting State independent personal servicesservices from a fixed base situated therein, and the technical fees are effectively connected with such permanent establishment or such servicesfixed base. In such case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 45. Technical fees shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority thereof, or a resident of that State. Where, however, the person paying the technical fees, whether he is a resident of the that Contracting State or not, has in a that Contracting State a permanent establishment or a fixed base in connection with which the obligation liability to pay the technical fees was incurred, and such technical fees are borne by such permanent establishmentestablishment or fixed base, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- last-mentioned amountamount of technical fees. 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 Agreement. 7. The provisions of this Article shall not apply if it was the main purpose or one of the main purposes of any person concerned with the creation or assignment of the rights in respect of which the technical fees are paid to take advantage of this Article by means of that creation or assignment.

TECHNICAL FEES. (1. ) Technical fees derived from one of the Contracting States contracting states by a resident of the other Contracting State contracting state who is the beneficial owner thereof and is subject to tax in that other State state in respect thereof may be taxed in the first-mentioned Contracting State contracting state at a rate not exceeding 10 per cent 8% of the gross amount of the technical fees. (2. ) The term " ‘technical fees " fees’ as used in this Article article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. (3. ) The provisions of paragraph 1 (1) of this Article article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting Statecontracting state, carries on business in the other Contracting State contracting state in which the technical fees arise through a permanent establishment situated therein, or performs in that other State state independent personal servicesservices from a fixed base situated therein, and the technical fees are effectively connected with such permanent establishment or such servicesfixed base. In such case, the provisions of Article 7 or Article 15, as the case may be, shall apply. (4. ) Technical fees shall be deemed to arise in a Contracting State contracting state when the payer is that State state itself, a statutory body thereof, a political subdivision, a local authority thereof, or a resident of that Statestate. Where, however, the person paying the technical fees, whether he is a resident of the Contracting State a contracting state or not, has in a Contracting State contracting state a permanent establishment or fixed base in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such permanent establishmentestablishment or fixed base, then such technical fees shall be deemed to arise in the Contracting State contracting state in which the permanent establishment or fixed base is situated. (5. ) Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article 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 Statecontracting state, due regard being had to the other provisions of this Agreementagreement.

TECHNICAL FEES. 1. Technical fees derived from one arising in a Contracting State and paid to a resident of the other contracting state may be taxed in that State. 2. However, such technical fees may also be taxed in the Contracting States by State in which they arise, and according to the laws of that State; but if the beneficial owner of the technical fees is a resident of the other Contracting State who is State, the beneficial owner thereof and is subject to tax in that other State in respect thereof may be taxed in the first-mentioned Contracting State at a rate so charged shall not exceeding exceed 10 per cent of the gross amount of the technical fees. 23. The term " "technical fees fees" as used in this Article means payments of any kind other than those referred to in other Articles of this Agreement to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 34. The provisions of paragraph paragraphs 1 and 2 of this Article Article, shall not apply if the beneficial owner recipient of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise arise, through a permanent establishment situated therein, therein or performs in that other State independent personal services, services from a fixed base situated therein and the technical fees are effectively connected with such permanent establishment or such servicesfixed base. In such a case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 45. Technical fees shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority thereof, or a resident of that State. Where, however, the person paying the technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such that permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 56. Where, Where by reason of a special relationship between the payer and the beneficial owner recipient or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever reason, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- 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 Agreement.

TECHNICAL FEES. 1. Technical fees arising in a Contracting State which are derived from one by a resident of the other Contracting States State may be taxed in that other State. 2. However, such technical fees may also be taxed in the Contracting State in which they arise, and according to the laws of that State, but where such technical fees are derived by 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 thereof, the tax charged in the first-mentioned Contracting State at a rate in which the technical fees arise shall not exceeding exceed 10 per cent of the gross amount of the technical such fees. 23. The term " “technical fees " fees” as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for of any services of a an administrative, technical, managerial or consultancy nature. 34. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner recipient of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services, and the technical fees are effectively connected with such permanent establishment or such servicesestablishment. In such case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 45. Technical fees shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority thereof, thereof or a resident of that State. Where, however, the person paying the technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such that permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner recipient or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner recipient 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 Agreement.

TECHNICAL FEES. 1. Technical fees derived from one of the arising in a Contracting States by State and paid to a resident of the other Contracting State who may be taxed in that other State. 2. However, such technical fees 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 and is subject to of the technical fees, the tax in that other State in respect thereof may be taxed in the first-mentioned Contracting State at a rate so charged shall not exceeding exceed 4[ 10 per cent cent] of the gross amount of the technical fees. 23. The term " "technical fees fees" as used in this Article means payments of any kind to any person, person other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 34. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply apply, if the beneficial owner of the technical fees, fees being a resident of a Contracting State, State carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, or performs in that other State independent personal services, services and the technical fees are effectively connected with such permanent establishment or such services. In such case, case the provisions of Article 7 or Article 15, as the case may be, shall apply. 45. Technical fees shall be deemed to arise in a Contracting State when the payer payee 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 technical fees, fees whether he is a resident of the a Contracting State or not, has in a resident of a Contracting State a permanent establishment or a fixed base in connection with which the obligation to pay the technical fees was incurred, incurred and such technical fees are borne by such that permanent establishment, establishment or fixed base then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner owner, or between both of them and some other persons, persons the amount of the technical fees paid exceedspaid, exceeds for what ever reasonwhatever reasons, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- last-mentioned amount. In such case, the excess part of the payments payment shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

TECHNICAL FEES. 1. Technical fees derived from one of the Fees for technical services arising in a Contracting States by 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 that other State. 2. However, notwithstanding the first-mentioned provisions of Article 7 and subject to the provisions of Articles 8, 16 and 17, fees for technical services arising in a Contracting State at may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the beneficial owner of the fees is a rate resident of the other Contracting State, the tax so charged shall not exceeding 10 per cent exceed 10% of the gross amount of the technical fees. 23. The term " “fees for technical fees " services” as used in this Article means payments any payment in consideration for any service of any kind to any persona managerial, other than contractual, technical, agency, professional 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 technical, managerial or consultancy naturean individual. 34. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the fees for technical feesservices, being a resident of a Contracting State, carries on business in the other Contracting State in which the fees for technical fees services arise through a permanent establishment situated therein, or performs in that other State independent personal services, and the fees for technical fees services are effectively connected with such permanent establishment or such servicesestablishment. In such case, case the provisions of Article 7 or Article 15, as the case may be, shall apply. 45. Technical 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 thereof, or a resident of that State. Where, however, State or if the person paying the technical fees, whether he that person is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation obligations to pay the technical fees was incurred, and such technical fees are borne by such the permanent establishment. 6. For the purposes of this Article, then such fees for technical fees services shall be deemed not to arise in the a Contracting State if the payer is a resident of that State and carries on business in which the other Contracting State or a third State through a permanent establishment is situatedsituated in that other State or the third State and such fees are borne by that permanent establishment. 57. 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 personsperson, the amount of the technical fees paid exceedsfees, having regard to the services for what ever reasonwhich they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- 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 Agreement.

TECHNICAL FEES. 1. Technical fees derived from one of the arising in a Contracting States by State and paid to a resident of the other Contracting State who may be taxed in that other State. 2. However, such technical fees 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 and is subject to of the technical fees the tax in that other State in respect thereof may be taxed in the first-mentioned Contracting State at a rate so charged shall not exceeding 10 exceed 15 per cent of the gross amount amounts of the technical fees. 23. The term " “technical fees " fees” as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 34. The provisions of paragraph paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, or performs in that other State independent independents personal services, and the technical fees are effectively connected with such permanent establishment or such services. In such case, case the provisions of Article 7 or Article 15, as the case may be, shall apply. 45. Technical fees shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority thereof, or a resident of that State. Where, however, the person paying the technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- 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 Agreement.

TECHNICAL FEES. 1. Technical fees derived from one of the Contracting States by 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 Contracting State at a rate not exceeding 10 per cent of the gross amount of the technical fees. 2. The term " "technical fees fees" as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 3. The provisions of paragraph 1 of this Article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, or performs in that other State independent personal services, and the technical fees are effectively connected with such permanent establishment or such services. In such case, case the provisions of Article 7 or Article 15, as the case may be, shall apply. 4. Technical fees shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority thereof, or a resident of that State. Where, however, the person paying the technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

TECHNICAL FEES. 1. 1. Technical fees derived from one arising in a Contracting State and paid to a resident of the other contracting state may be taxed in that State. 2. 2. However, such technical fees may also be taxed in the Contracting States by State in which they arise, and according to the laws of that State; but if the beneficial owner of the technical fees is a resident of the other Contracting State who is State, the beneficial owner thereof and is subject to tax in that other State in respect thereof may be taxed in the first-mentioned Contracting State at a rate so charged shall not exceeding exceed 10 per cent of the gross amount of the technical fees. 23. 3. The term " "technical fees fees" as used in this Article means payments of any kind other than those referred to in other Articles of this Agreement to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 34. 4. The provisions of paragraph paragraphs 1 and 2 of this Article Article, shall not apply if the beneficial owner recipient of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise arise, through a permanent establishment situated therein, therein or performs in that other State independent personal services, services from a fixed base situated therein and the technical fees are effectively connected with such permanent establishment or such servicesfixed base. In such a case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 45. 5. Technical fees shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority thereof, or a resident of that State. Where, however, the person paying the technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such that permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 56. Where, 6. Where by reason of a special relationship between the payer and the beneficial owner recipient or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever reason, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- 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 Agreement.

TECHNICAL FEES. 1. Technical fees derived from one of the arising in a Contracting States by State and paid to a resident of the other Contracting State who may be taxed in that other State. 2. However, such technical fees 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 and is subject to of the technical fees the tax in that other State in respect thereof may be taxed in the first-mentioned Contracting State at a rate so charged shall not exceeding 10 exceed 7.5 per cent of the gross amount amounts of the technical fees. 23. The term " "technical fees fees" as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 34. The provisions of paragraph paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise through thorough a permanent establishment situated therein, or performs in that other State independent personal services, and the technical fees are effectively connected with (a) such permanent establishment or such servicesfixed base or with (b) business activities referred to under subparagraph (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. 45. Technical fees shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority thereof, or a resident of that State. Where, however, the person paying the technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- 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 Agreement.

TECHNICAL FEES. (1. ) Technical fees derived from one of the arising in a Contracting States by State and paid to a resident of the other Contracting State who is may be taxed in that other State. (2) However, such technical fees may also be taxed in the Contracting State in which they arise and according to the law of that State, but if the beneficial owner thereof of the technical fees is a resident of, and is subject to tax in that respect of the technical fees in, the other State in respect thereof may be taxed in Contracting State, the first-mentioned Contracting State at a rate tax so charged shall not exceeding 10 exceed 7.5 per cent of the gross amount of the technical fees. 2. (3) The term " "technical fees fees" as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a an administrative, technical, managerial or consultancy nature. 3. (4) The provisions of paragraph 1 paragraphs (1) and (2) of this Article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise arise, through a permanent establishment situated therein, or performs in that other State independent personal servicesservices from a fixed base situated therein, and the technical fees are effectively connected with such permanent establishment or such servicesfixed base. In such case, case the provisions of Article 7 or Article 1515 of this Convention, as the case may be, shall apply. 4. (5) Technical fees shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority thereof, or a resident of that State. Where, however, the person paying the technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such that permanent establishmentestablishment or fixed base, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 5. (6) Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- 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 AgreementConvention. (7) The provisions of this Article shall not apply if it was the main purpose or one of the main purposes of any person concerned with the creation or assignment of the rights in respect of which the technical fees are paid to take advantage of this Article by means of that creation or assignment.

TECHNICAL FEES. 1. Technical Notwithstanding the provisions of Article 15, technical fees derived from one of the Contracting States by 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-first- mentioned Contracting State at a rate not exceeding 10 per cent 10% of the gross amount of the technical fees. 2. The term " "technical fees fees" as used in this the Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 3. The provisions of paragraph 1 of this Article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State estate in which the technical fees arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services, and the technical fees are effectively connected with such permanent establishment or such services. In such case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 4. Technical fees 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 technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- 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 Agreement.

TECHNICAL FEES. 1. Technical fees derived from one of the Contracting States by 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 Contracting State at a rate not exceeding 10 8 per cent of the gross amount of the technical fees. 2. The term " “technical fees " fees” as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 3. The provisions of paragraph 1 of this Article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, or performs in that other State independent personal servicesservices from a fixed base situated therein, and the technical fees are effectively connected with such permanent establishment or such servicesfixed base. In such case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 4. Technical fees shall be deemed to arise in a Contracting State when the payer is that State itself, a statutory body thereof, a political subdivision, a local authority thereof, or a resident of that State. Where, however, the person paying the technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment of fixed base in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such permanent establishmentestablishment or fixed base, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- 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 Agreement.

TECHNICAL FEES. 1. 1. Technical fees derived from one arising in a Contracting State and paid to a resident of the other contracting state may be taxed in that State. 2. 2. However, such technical fees may also be taxed in the Contracting States by State in which they arise, and according to the laws of that State; but if the beneficial owner of the technical fees is a resident of the other Contracting State who is State, the beneficial owner thereof and is subject to tax in that other State in respect thereof may be taxed in the first-mentioned Contracting State at a rate so charged shall not exceeding exceed 10 per cent of the gross amount of the technical fees. 23. 3. The term " "technical fees fees" as used in this Article means payments of any kind other than those referred to in other Articles of this Agreement to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 34. 4. The provisions of paragraph paragraphs 1 and 2 of this Article Article, shall not apply if the beneficial owner recipient of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise arise, through a permanent establishment situated therein, therein or performs in that other State independent personal services, services from a fixed base situated therein and the technical fees are effectively connected with such permanent establishment or such servicesfixed base. In such a case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 45. 5. Technical fees shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority thereof, or a resident of that State. Where, however, the person paying the technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such that permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 56. Where, 6. Where by reason of a special relationship between the payer and the beneficial owner recipient or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever reason, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

TECHNICAL FEES. 1. Technical fees derived from one of the arising in a Contracting States by 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 that other Contracting State. 2. However, such technical fees may also be taxed in the first-mentioned Contracting State at in which they arise and according to the laws of that Contracting State, but if the beneficial owner of the technical fees is a rate resident of the other Contracting State, the tax so charged shall not exceeding 10 exceed ten (10) per cent of the gross amount amounts of the technical fees. 23. The term " “technical fees " fees” as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 34. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, or performs in that other Contracting State independent personal servicesservices from a fixed base situated therein, and the technical fees are effectively connected with (a) such permanent establishment or such servicesfixed base, or (b) business activities referred to in (c) of paragraph 1 of Article 7. In such casecases, the provisions of Article 7 or Article 15, as the case may be, shall apply. 45. Technical fees shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority thereof, itself or a resident of that State. Where, however, the person paying the technical fees, whether he is a resident of the 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 pay the technical fees was incurred, and such technical fees are borne by such that permanent establishmentestablishment or fixed base, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- last-mentioned amountamount of the technical fees. 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 Agreement. 7. The provisions of this Article shall not apply if it was the main purpose or one of the main purposes of any person concerned with the creation or assignment of the rights in respect of which the technical fees are paid to take advantage of this Article by means of that creation or assignment.

TECHNICAL FEES. 1. Technical fees arising in a Contracting State which are derived from one of the Contracting States by 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 that other State. 2. However, such technical fees may also be taxed in the first-mentioned Contracting State at a rate in which they arise, and according to the laws of that State; but if the recipient is the beneficial own of the technical fees, the tax so charged shall not exceeding exceed 10 per cent of the gross amount of the technical fees. 23. The term " "technical fees fees" as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 34. The provisions of paragraph 1 of this Article paragraphs (1) and (2) shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, State carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, or performs in that other State independent personal services, and the technical fees are effectively connected with such permanent establishment or such services. In such case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 45. Technical fees 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 technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such that permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner recipient or between both of them and some other personsperson, the amount of the technical fees paid exceedspaid, exceeds for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- 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 Agreement.

TECHNICAL FEES. 1. Technical fees derived from one of the arising in a Contracting States by State and paid to a resident of the other Contracting State who is may be taxed in that other State. 2. However, such technical fees may also be taxed in the Contracting State in which they arise and according to the law of that State, but if the beneficial owner thereof and is subject to tax in that other State in respect thereof may be taxed of the technical fees in the first-mentioned other Contracting State at a rate State, the tax so charged shall not exceeding exceed 10 per cent of the gross amount of the technical fees. 23. The term " "technical fees fees" as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 34. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise arise, through a permanent establishment situated therein, or performs in that other State independent personal servicesservices from a fixed base situated therein, and the technical fees are effectively connected with such permanent establishment or such servicesfixed base. In such case, case the provisions of Article 7 or Article 15, as the case may be, shall apply. 45. Technical fees shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivisionsub-division, a local authority thereof, or a resident of that State. Where, however, the person paying the technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such that permanent establishmentestablishment or fixed base, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever reason, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- 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 Agreement.

TECHNICAL FEES. 1. Technical fees derived from one of the arising in a Contracting States by 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 that other State. 2. However, such technical fees may also be taxed in the first-mentioned Contracting State at in which they arise, and according to the laws of that State, but if the beneficial owner of the technical fees is a rate resident of the other Contracting State, the tax so charged shall not exceeding exceed 10 per cent of the gross amount of the technical fees. 23. The term " "technical fees fees" as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services service of a technical, managerial or consultancy nature. 34. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services, therein and the technical fees are effectively connected with such permanent establishment or such servicesestablishment. In such case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 45. Technical fees shall be deemed to arise in a Contracting State when where the payer is that State itself, a political subdivision, a local authority thereof, or a resident of that State. Where, however, the person paying the technical fees, whether he that person is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such the permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever reason, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- 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 Agreement.

TECHNICAL FEES. 1. Technical fees derived from one of the arising in a Contracting States by State and paid to a resident of the other Contracting State who is may be taxed in that other State. 2. However, such technical fees may also be taxed in the Contracting State in which they arise, and according to the law of that State, but if the beneficial owner thereof and is subject to tax in that other State in respect thereof may be taxed of the technical fees in the first-mentioned other Contracting State at a rate State, the tax to charged shall not exceeding exceed 10 per cent of the gross amount of the technical fees. The competent authorities of the Contracting States shall settle the mode of application of this limitation by mutual agreement. 23. The term " “technical fees " fees” as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services service of a technical, managerial or consultancy nature. 34. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services, therein and the technical fees are effectively connected with such permanent establishment or such servicesestablishment. In such case, case the provisions of Article 7 or Article 15, as the case may be, shall apply. 45. Technical fees shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority thereof, or a resident of that State. Where, however, the person paying the technical fees, whether he that person is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such that permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever reason, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- 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 Agreement.

TECHNICAL FEES. 1. Technical fees derived from one of the Contracting States by 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 Contracting State at a rate State. However, the tax so charged shall not exceeding 10 per cent exceed 5 percent of the gross amount of the technical fees. 2. The term " "technical fees fees" as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 3. The provisions of paragraph 1 of this Article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise arise, through a permanent establishment situated therein, or performs in that other State independent personal servicesservices from a fixed base situated therein, and the technical fees are effectively connected with such permanent establishment or such servicesfixed base. In such case, the provisions of Article 7 or Article 1514, as the case may be, shall apply. 4. Technical fees shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority thereof, or a resident of that State and the services are performed in that State. Where, however, the person paying the technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such permanent establishmentestablishment or fixed base, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situatedsituated if the services are performed in that State. 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws law of each Contracting State, due regard being had to the other provisions of this Agreement.

TECHNICAL FEES. 1. Technical fees derived from one of the arising in a Contracting States by 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 that other Contracting State. 2. However, such technical fees may also be taxed in the first-mentioned Contracting State at in which they arise and according to the laws of that Contracting State, but if the beneficial owner of the technical fees is a rate resident of the other Contracting State, the tax so charged shall not exceeding exceed 10 per cent of the gross amount of the technical fees. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation. 23. The term " "technical fees fees" as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration considera- tion for any services of a technical, managerial or consultancy nature. 34. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other oth- er Contracting State in which the technical fees arise through a permanent establishment situated therein, or performs in that other Contracting State independent personal servicesser- vices from a fixed base situated therein, and the technical fees are effectively connected with such permanent establishment or such servicesfixed base. In such case, case the provisions of Article 7 or Article 15, as the case may be, shall apply. 45. Technical fees shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority thereof, or a resident of that State. Where, however, the person paying the technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment or fixed base in connection with which the obligation liability to pay the technical fees was incurred, and such technical fees are borne by such permanent establishmentestablishment of fixed base, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- 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 AgreementConvention.

TECHNICAL FEES. 1. Technical fees derived from one of the arising in a Contracting States by State and paid to a resident of the other Contracting State who may be taxed in that other State. 2. However, such technical fees 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 and is subject to of the technical fees the tax in that other State in respect thereof may be taxed in the first-mentioned Contracting State at a rate so charged shall not exceeding 10 exceed 15 per cent of the gross amount amounts of the technical fees. 23. The term " “technical fees " fees” as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 34. The provisions of paragraph paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise through thorough a permanent establishment situated therein, or performs in that other State independent personal services, and the technical fees are effectively connected with such permanent establishment or such services. In such case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 45. Technical fees shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority thereof, or a resident of that State. Where, however, the person paying the technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- 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 Agreement.

TECHNICAL FEES. 1. Technical fees derived from one of the arising in a Contracting States by State and paid to a resident of the other Contracting State who may be taxed in that other State. 2. However, such technical fees 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 and is subject to of the technical fees the tax in that other State in respect thereof may be taxed in the first-mentioned Contracting State at a rate shall not exceeding 10 exceed 15 per cent of the gross cross amount of the technical fees. 23. The term " “technical fees " fees” as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 34. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise arise, through a permanent establishment situated therein, or performs in that other State independent personal servicesservices from a fixed base situated therein, and the technical fees are effectively connected with such permanent establishment or such servicesfixed base. In such case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 45. If a resident of one of the Contracting States, who receives and beneficially owns technical fees which arise in the other Contracting State, so elects for any year of assessment, financial year or year of income, the tax in respect of those technical fees in the Contracting State in which they arise shall be calculated in the last-mentioned Contracting State and as if those technical fees were taxable in accordance with Article 7 or Article 15, as the case may be, as profits attributable to that permanent establishment or fixed base. 6. Technical fees 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 technical fees, whether he the person is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such that permanent establishmentestablishment or fixed base, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 57. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- 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 Agreement.

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

TECHNICAL FEES. 1. Technical fees arising in a Contracting State which are derived from one of the Contracting States by a resident of the other Contracting State who may be taxed in that other State. 2. However, such technical fees 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 and is subject to of the technical fees, the tax in that other State in respect thereof may be taxed in the first-mentioned Contracting State at a rate so charged shall not exceeding exceed 10 per cent of the gross amount of the technical fees. 23. The term " "technical fees fees" as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 34. The provisions of paragraph paragraphs 1 of this Article and 2 shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, State carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, or performs in that other State independent personal services, and the technical fees are effectively connected with such permanent establishment or such services. In such case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 45. Technical fees 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 technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such that permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner recipient or between both of them and some other personsperson, the amount of the technical fees paid exceedspaid, exceeds for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws law of each Contracting State, State due regard being had to the other provisions of this Agreement.

TECHNICAL FEES. 1. Technical fees derived from one of the arising in a Contracting States by 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-first mentioned Contracting State at a rate State. The tax so charged shall not exceeding 10 per cent exceed 7.5 percent of the gross amount of the technical fees. 2. The term " “technical fees " fees” as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 3. The provisions of paragraph 1 of this Article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, or performs in that other State independent personal services, and the technical fees are effectively connected with such permanent establishment or such services. In such case, case the provisions of Article 7 or Article 15, as the case may be, shall apply. 4. Technical fees shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority thereof, or a resident of that State. Where, however, the person paying the technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such permanent establishmentestablishment or fixed base, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- 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 Agreement.

TECHNICAL FEES. 1. Technical fees arising in a Contracting State which are derived from one of the Contracting States by 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 that other State. 2. However, such technical fees may also be taxed in the first-mentioned Contracting State at in which the arise, and according to the laws of that State, but if the beneficial owner of the technical fees is a rate resident of the other Contracting State, the tax so charged shall not exceeding exceed 10 per cent percent of the gross amount of the technical fees. 23. The term " “technical fees " fees” as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a an administrative, technical, managerial or consultancy naturenature performed outside that State. 34. The provisions of paragraph paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services, therein and the technical fees are effectively connected with such permanent establishment or such servicesestablishment. In such case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 45. Technical fees shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority thereof, or a resident of that State. Where, however, the person paying the technical fees, whether he that person is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such that permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 56. Where, Where by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- 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 Agreement.

TECHNICAL FEES. 1. Technical fees derived derives from one of the Contracting States State by a 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 the first-first- mentioned Contracting State at a rate not exceeding 10 per cent of the gross amount of the technical fees. 2. The term " "technical fees fees" as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services of a technical, managerial or consultancy nature. 3. The provisions of paragraph 1 of this Article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, or performs in that other Contracting State independent personal services, and the technical fees are effectively connected with such permanent establishment or such services. In such case, the provisions of Article 7 or Article 1514, as the case may be, shall apply. 4. Technical fees shall be deemed to arise in a Contracting State when the payer is that Contracting State itself, a political subdivision, a local authority or a statutory body thereof, or a resident of that Contracting State. Where, however, the person paying the technical fees, whether he is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever whatever reason, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- 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 Agreement.

TECHNICAL FEES. 1. Technical fees derived from one of the arising in a Contracting States by 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 that other State. 2. However, such technical fees may also be taxed in the first-mentioned Contracting State at in which they arise, and according to the laws of that State, but if the beneficial owner of the technical fees is a rate resident of the other Contracting State, the tax so charged shall not exceeding 10 exceed 5 per cent of the gross amount of the technical fees. 23. The term " “technical fees " fees” as used in this Article means payments of any kind to any person, other than to an employee of the person making the payments, in consideration for any services service of a an administrative, technical, managerial or consultancy nature. 34. The provisions of paragraph paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise arise, through a permanent establishment situated therein, or performs in that other State independent personal services, therein and the technical fees are effectively connected with such permanent establishment or such servicesestablishment. In such case, the provisions of Article 7 or Article 15, as the case may be, shall apply. 45. Technical fees shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority thereof, or a resident of that State. Where, however, the person paying the technical fees, whether he that person is a resident of the a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such the permanent establishment, then such technical fees shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 56. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other personsperson, the amount of the technical fees paid exceeds, for what ever reason, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last- 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 Agreement.