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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Article 12: Tax on Royalties and Technical Services Capped 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. These payments, made to a resident of one Contracting State by a resident of the other, may be taxed in both States, but the tax in the source State is capped at 10% if the recipient is the beneficial owner. The terms 'royalties' and 'fees for technical services' are defined to include payments for the use of intellectual property and technical services, respectively. Exceptions apply if the recipient has a permanent establishment in the source State. Special provisions address payments influenced by relationships between parties.
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