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of <h1>Article 12: Taxation of Royalties and Technical Fees in Double Tax Agreement with 10% Cap for Beneficial Owners.</h1> Article 12 of the Double Tax Avoidance Agreement between Romania and another Contracting State addresses the taxation of royalties and fees for technical services. Such payments may be taxed in the state where they arise and also in the state where the recipient resides, with a maximum tax rate of 10% in the state of origin if the recipient is the beneficial owner. Royalties are defined as payments for the use of intellectual property, while fees for technical services refer to payments for managerial, technical, or consultancy services. Exceptions apply if the recipient has a permanent establishment in the source state.
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