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of <h1>Article 12 of DTAA Limits Source State Tax on Royalties and Technical Service Fees to 10% for Beneficial Owners.</h1> Article 12 of the Double Tax Avoidance Agreement (DTAA) between two Contracting States addresses the taxation of royalties and fees for technical services. Such payments arising in one State and paid to a resident of the other State may be taxed in both States, but the tax in the source State should not exceed 10% if the recipient is the beneficial owner. 'Royalties' include payments for the use of copyrights, patents, and other intellectual properties, while 'fees for technical services' cover payments for managerial, technical, or consultancy services. Exceptions apply if the recipient conducts business through a permanent establishment in the source State.
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