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of <h1>Article 12 Caps Tax on Royalties and Technical Fees at 10% Under Double Tax Avoidance Agreement</h1> Article 12 of the Double Tax Avoidance Agreement between two contracting states addresses the taxation of royalties and fees for technical services. Such payments, when made to a resident of the other state, may be taxed in both states but are capped at 10% in the state where they arise if the beneficial owner resides in the other state. Royalties cover payments for the use of intellectual property and certain equipment, excluding aircraft and ships, while fees for technical services include managerial and consultancy services. Exceptions apply if the beneficial owner has a permanent establishment or fixed base in the state where the payments arise.
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