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of <h1>Taxation of Royalties and Technical Fees Under Article 12 of DTAA: 10% Cap on Source State Taxation</h1> Article 12 of the Double Taxation Avoidance Agreement (DTAA) between two contracting states addresses the taxation of royalties and fees for technical services. Such payments, originating in one state and paid to a resident of the other, may be taxed in both states. However, if the beneficial owner is a resident of the other state, the tax in the originating state is capped at 10% of the gross amount. The article defines 'royalties' and 'fees for technical services' and outlines exceptions where these provisions do not apply, such as when business is conducted through a permanent establishment. Additionally, it addresses cases of special relationships affecting payment amounts.
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