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Taxation of income from serviceson a gross basis. 81 As noted above, the 2011 study by the IBFD found that134 of 1,586 tax treaties concluded between 1997 and 2011 contained aseparate article dealing with fees for technical services. 82 Several othertreaties extended the provisions of Article 12 dealing with royalties toinclude certain technical services. Under the separate articles, incomefrom technical services is treated like royalties. Source country tax isallowed on a gross basis at a fixed rate that varies; sometimes the rateis higher than the rate on royalties and sometimes lower. Typically,source country tax is limited to fees for technical services “arising” inthe source country, which usually means that the services must be performedtherein. As noted above, typically these separate articles dealingwith fees for technical services refer to “managerial, technical or consultancyservices” without defining that expression.In general, business profits and income from professional andindependent services are taxable under the provisions of the UnitedNations Model Convention only if the non-resident service providerhas a PE or fixed base in the source country and is taxable on a net basis.Notwithstanding this general pattern, there seems to be widespread recognitionthat source countries should be entitled to tax interest, royaltiesand fees for technical services that constitute business profits, even in theabsence of a PE or a fixed base, probably because these payments reducethe source country’s tax base. This recognition is reflected in the decisionof the United Nations Committee of Experts to work on a new article toallow source countries to tax income from technical services on a basissimilar to the taxation of royalties (that is to say, on a gross basis at alimited rate without any threshold requirement, even if the services areprovided outside the source country). If a new article with these featuresis added to the United Nations Model Convention and developing countriesare successful in negotiating the inclusion of the new article in theirtax treaties, such countries will be able to tax income from technical servicesearned by non-residents and protect their domestic tax base from81In some cases, the definition of royalties is amended to include technicalfees; in other cases, a separate article dealing with technical fees is addedto a tax treaty. See S. B. Law, “Technical Services Fees in Recent Tax Treaties,”(2010) Vol. 64, No. 5 Bulletin for International Taxation, at 250 – 52.82See W. Wijnen, J. de Goede and A. Alessi, “The Treatment of Servicesin Tax Treaties,” supra note 72.95