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of <h1>Article 12: Taxation Rules for Royalties and Service Fees in Double Taxation Avoidance Agreement Explained</h1> Article 12 of the Double Taxation Avoidance Agreement addresses the taxation of royalties and fees for included services between two Contracting States. Such payments can be taxed in both the State where they arise and the State of the recipient's residence, with tax rates capped at specified percentages depending on the nature of the payer and the type of royalties or services. The article defines 'royalties' and 'fees for included services,' outlining exclusions and conditions under which these provisions do not apply, such as when the recipient has a permanent establishment in the payer's State. The article also addresses situations involving special relationships affecting payment amounts.
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