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of <h1>Article 12 of DTAA: Taxation of Royalties in Contracting States with Limits and Conditions Defined</h1> Article 12 of the Double Taxation Avoidance Agreement (DTAA) between two Contracting States addresses the taxation of royalties. Royalties arising in one state and beneficially owned by a resident of the other state may be taxed in both states, with specific limits on the tax rate. The term 'royalties' encompasses payments for the use of intellectual property, equipment, and related services, but excludes certain ancillary services. The article outlines conditions under which royalties are deemed to arise in a state and addresses situations involving permanent establishments. It also specifies treatment for royalties influenced by special relationships between parties.
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