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of <h1>Article 13 of DTAA Limits Tax on Technical Service Fees to 10% for Beneficial Owners; Defines Exclusions and Exceptions.</h1> Article 13 of the Double Tax Avoidance Agreement (DTAA) between two Contracting States addresses the taxation of fees for technical services. Such fees, when arising in one Contracting State and paid to a resident of the other, may be taxed in both States, but the tax in the State of origin is capped at 10% if the recipient is the beneficial owner. The definition of 'fees for technical services' excludes payments covered by other specified articles and includes managerial, technical, or consultancy services. Exceptions apply if the fees relate to a permanent establishment or fixed base in the State of origin. The article also addresses cases involving special relationships that affect fee amounts.
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