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of <h1>Korea DTAA Article 12 limits tax on cross-border royalties and technical service fees to 10% for beneficial owners.</h1> Article 12 of the Double Tax Avoidance Agreement (DTAA) between Korea and another Contracting State addresses the taxation of royalties and fees for technical services. These payments, when originating in one State and paid to a resident of the other, may be taxed in both States. However, if the recipient is the beneficial owner and a resident of the other 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 the payments are connected to a permanent establishment. It also addresses situations involving special relationships that may affect payment amounts.
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