Furthermore, any definition of technical services in this context raises an inevitable question
about the very basic concept of the service PE contained in Article 5(3)(b): why would a time
threshold be needed to justify the taxing right of a source country under the PE concept if
another Article grants a taxing right for services with no regard to any such requirements?
Any definition, moreover, needs to avoid conflicting interpretations and should be aligned
with the definition of “royalties” under Article 12 so that the same function cannot fall within
both definitions, potentially subjecting the taxpayers to double or multiple levels of taxation.