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of <h1>Uruguay's DTAA Article 12 Caps Tax on Royalties, Technical Fees at 10% for Beneficial Owners Without Local Establishments</h1> Article 12 of the Double Tax Avoidance Agreement (DTAA) between Uruguay and another Contracting State addresses the taxation of royalties and fees for technical services. These payments, originating in one Contracting State and paid to a resident of the other, may be taxed in both states. However, if the beneficial owner is 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 conditions under which these provisions do not apply, such as when the beneficial owner has a permanent establishment in the originating state.
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