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of <h1>Article 12 of DTAA Limits Tax on Royalties and Technical Service Fees to 10% Between Macedonia and Partner State</h1> Article 12 of the Double Tax Avoidance Agreement (DTAA) between Macedonia and another Contracting State addresses the taxation of royalties and fees for technical services. These payments, arising in one Contracting State and paid to a resident of the other, may be taxed in both states but are capped at ten percent in the state where they arise if the recipient is a resident of the other state. 'Royalties' cover payments for the use of intellectual property, while 'fees for technical services' include payments for managerial, technical, or consultancy services. Exceptions apply if the recipient has a permanent establishment in the state where the payment arises.
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