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of <h1>DTAA Article 12: Royalties Tax Capped at 10% for Beneficial Owners; Includes Copyrights, Patents, Trademarks. Exceptions Apply.</h1> Article 12 of the Double Tax Avoidance Agreement (DTAA) between Thailand and another Contracting State addresses the taxation of royalties. Royalties paid to a resident of one Contracting State may be taxed in the other State, but the tax should not exceed 10% if the recipient is the beneficial owner. Royalties include payments for the use of copyrights, patents, trademarks, and similar rights. Exceptions apply if the beneficial owner has a permanent establishment in the State where the royalties arise. The article also addresses situations involving special relationships that may affect royalty amounts.
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