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of <h1>Colombia's DTAA Article 12 Caps Tax on Royalties and Technical Fees at 10% for Beneficial Owners in Other State.</h1> Article 12 of the Double Tax Avoidance Agreement (DTAA) between Colombia and another Contracting State addresses the taxation of royalties and fees for technical services. These payments, originating in one Contracting State and paid to a resident of the other, may be taxed in both states. However, if the beneficial owner resides in the other Contracting 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 operations are conducted through a permanent establishment.
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