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of <h1>Article 13 of DTAA: Tax on Royalties and Technical Fees Capped at 30% if Beneficial Owner is Resident</h1> Article 13 of the Double Tax Avoidance Agreement (DTAA) between Great Britain and Northern Ireland addresses the taxation of royalties and fees for technical services. These payments, when arising in one Contracting State and paid to a resident of the other, may be taxed in both States, with a maximum tax rate of 30% in the source State if the recipient is the beneficial owner. Royalties include payments for the use of intellectual property and certain equipment but exclude those related to natural resources. Fees for technical services cover managerial, technical, or consultancy services. Specific provisions apply if the recipient conducts business through a permanent establishment in the source State. Payments are considered to arise where the payer resides, unless linked to a permanent establishment elsewhere. Excess payments due to special relationships are only partially covered by this Article.
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