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of <h1>Taxation on Royalties and Fees Under Article 12 of DTAA: 10% Cap and Special Relationship Clauses Explained</h1> Article 12 of the Double Taxation Avoidance Agreement (DTAA) between Austria and another Contracting State addresses taxation on royalties and fees for technical services. These payments, if arising in one Contracting State and paid to a resident of the other, may be taxed in the recipient's state but also in the state where they arise, with a tax cap of 10% if the recipient is the beneficial owner. The article defines 'royalties' and 'fees for technical services' and specifies conditions under which these provisions do not apply, particularly when the recipient has a permanent establishment in the state where the payments arise. It also addresses situations involving special relationships affecting payment amounts.
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