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of <h1>Taxation of Royalties and Technical Fees Capped at 10% in DTAA Article 12 for Beneficial Owners</h1> Article 12 of the Double Tax Avoidance Agreement (DTAA) between two territories addresses the taxation of royalties and fees for technical services. These payments, if arising in one territory and paid to a resident of the other, may be taxed in both territories. However, if the beneficial owner resides in the other territory, the tax in the source territory is capped at 10% of the gross amount. The article defines 'royalties' and 'fees for technical services' and outlines conditions under which these provisions do not apply, especially when a permanent establishment or fixed base is involved. It also addresses scenarios involving special relationships that may affect payment amounts.
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