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of <h1>Article 12 of DTAA: Royalties and technical service fees taxed in both States, capped at 10% if beneficial owner resides elsewhere.</h1> Under Article 12 of the Double Tax Avoidance Agreement (DTAA) between two Contracting States, royalties and fees for technical services paid to a resident of one State by a resident of the other may be taxed in both States. However, if the beneficial owner resides in the other State, taxation in the source State is capped at 10% of the gross amount. 'Royalties' include payments for the use of intellectual property, while 'fees for technical services' cover managerial, technical, or consultancy services. Exceptions apply if the beneficial owner has a permanent establishment in the source State. Payments exceeding fair market value due to special relationships are taxable under each State's laws.
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